Privacy Policy

1. Purpose

In compliance with the provisions of 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 (hereinafter GDPR) and other applicable regulations, VBOTE INNOVATION S.L. (hereinafter VBOTE), wishes to inform users of the website www.tweem.com (hereinafter, the site or website) of its policy regarding the treatment and protection of personal data of those persons who provide their personal data through the personalized use or registration of the site's services or any other act that involves communication of their personal data to VBOTE (hereinafter also, Policy or Privacy Policy).

VBOTE informs the site user that this Privacy Policy contains a general description of the aspects related to the processing of personal data derived from the exploitation of VBOTE's website that this entity carries out as responsible for such processing.

This policy is supplemented by those informative texts and informed consent request texts that may be incorporated into any data request form on the website or included in any particular conditions for use of certain services.

It is the user's responsibility to read carefully before communicating their personal data to VBOTE the aforementioned informative texts and consent request texts included in any data request form on the site as well as the content of this policy.

2. Mandatory or voluntary nature of data communication by the user

The use of this site is voluntary for the user but, this use is regulated by the general contractual conditions published on this site, both for use of the site and for privacy.

Consequently, the use of services on the website www.tweem.com, including those that require communication of data to VBOTE, is always voluntary, but conditioned by the terms and conditions of use and privacy that, therefore, are expressly and fully accepted by the site user and the services published on it.

If the user voluntarily decides to use any service on this website that requires the communication of personal data, such communication constitutes a contractual requirement derived from the acceptance of the terms and conditions that regulate the site, the user being obliged to provide the personal data that this site may request, and being informed that, otherwise, the possible consequences of not providing such data are fundamentally the impossibility of use of the requested web service.

In case the user does not agree with this policy or conditions of service, should not access or use any service of the site that requires the communication of their personal data to VBOTE.

Likewise, the user is informed that this policy will be subsidiarily applied to any other policies on the same matter that are established as special and/or particular and communicated to the user, without limitation, through registration forms, contracting conditions or conditions of particular services, with this policy being supplementary to the previous ones in what does not contradict.

When the user must communicate their personal data to VBOTE through the forms published on the site, if the user does not provide all the data requested in each form or, where appropriate, does not provide those marked with an asterisk for mandatory completion, VBOTE will not or will not be able to adequately attend to the request made by the user and/or guarantee the use and enjoyment of the requested service.

Users are informed that any processing of personal data will fall under the scope of current Spanish legislation on data protection.

For these purposes, personal data shall be understood to mean any information concerning identified or identifiable natural persons – including email data and/or IP address – and user, any identified or identifiable natural person who communicates their personal data to VBOTE via email, customer service, curriculum vitae submission, completion of forms on this website and/or use of services aimed at users of this website.

3. Identifying data and contact information of the data controller

The person responsible for the processing of personal data carried out through the website or as a result of the use of its services is VBOTE INNOVATION S.L. (hereinafter VBOTE).

Contact details:

Address: Calle de la Barraca nº 41 bajo - 46011 Valencia
Email contact: info@vbote.com
Telephone: 963256879.

4. Data of minors or incapable persons

Minors under 16 years of age and incapable persons will not be able to use VBOTE's website services that require registration or identification without the representation of their father, mother, guardian or legal representative.

5. Accuracy and truthfulness of personal data

Users who access VBOTE's website are not obliged to provide personal information to use the site, therefore, any communication of data for these purposes will be because the user has voluntarily decided a personalized navigation or use of the site and/or the services made available to them through it.

In the event that the user provides VBOTE with their personal data, the user is obliged to provide truthful, current and accurate data that correspond to their own identity, being responsible for any data and information from third parties that they provide for the use of services made available to them through the site.

The user is solely responsible for the truthfulness, accuracy, updating and correction of the data they provide, exonerating VBOTE from any responsibility in this regard and undertaking to keep personal data properly updated.

The user accepts to provide truthful, updated, complete and correct information, always and exclusively corresponding to their own identity, through any data collection channel published on the site, such as registration, login or subscription forms, contact, suggestions, contracting and/or any other data request form on the site, including other means such as sending an email to VBOTE, through postal communication and/or by telephone.

The user is the sole source of information for their personal data, so VBOTE requests that, in order to keep their data updated and current at all times in accordance with the principles of data protection legislation, communicate to the postal and electronic addresses indicated below for the exercise of the rights stated in this Policy, any change in them. In any case, when data is collected or provided directly by the affected user, in accordance with current regulations, the data provided by them will be considered accurate, as long as the user does not update or correct it.

6. Use of geolocation

Tweem uses the device's location only at the moment of performing a check-in (START, STOP or MODIFICATION of an activity).

There is no continuous or background tracking.

The user must manually authorize access to location from their device; otherwise, geolocation-based features may not be available.

The location is obtained through the device and is used solely to validate the registration location, is retained only as long as necessary and is not shared with third parties, except by legal obligation.

7. Special categories of data

VBOTE neither requests nor requires special category data from users through the site, understanding by these, in accordance with current regulations, personal data that reveal race, ethnic or racial origin, political opinions, religious or philosophical convictions or beliefs, or trade union affiliation, genetic data, biometric data, data concerning physical or mental health, data concerning sex life or sexual orientations of a natural person, data concerning criminal convictions or offences.

In case VBOTE at any time requires this information from the user, the express consent of the user will be requested (either through a statement or a clear affirmative action), to collect and use that information by communicating to the user, prior and unequivocally, the purpose of the collection and processing of such information.

Consequently, in case for any reason, and without having been requested by VBOTE, such information is communicated voluntarily by the user to the aforementioned entity, such communication will constitute an explicit act of the user that implies the existence of an expression of express consent by the user regarding the processing of their data by VBOTE.

8. Purposes and legal bases for processing personal data

Users who access the website and voluntarily provide personal information to navigate the site in a personalized manner, contact, contract or use any service that requires communication of data to VBOTE, are informed of the following purposes and legal bases for processing user personal data that VBOTE may carry out:

On the legal basis of consent provided by the user when submitting their data, VBOTE may process their data for the following purposes:

Contact with VBOTE: When the user uses the services enabled for this purpose to contact VBOTE (through forms, telephone, postal or email), VBOTE will process their personal data to attend to and manage the response to the communication made by the user and provide them with the requested information.

Sending commercial communications: When the user authorizes or expressly consents, VBOTE will process their data to send them advertising information, newsletters, news and invitations to events and commercial communications. The legal basis for the processing of this user data by VBOTE is the consent granted by the user by accepting the corresponding boxes prior to sending the completed form to VBOTE.

Selection of candidates: If the user sends their curriculum vitae, the data provided through the site and/or those requested through the procedure established on the website, will be processed by VBOTE for the purpose of assessing and, where appropriate, allowing their participation in selective processes developed by VBOTE.

On the basis of the contractual relationship established between VBOTE and the user who contracts with VBOTE for the use of an online service, VBOTE may carry out the processing of the user's data for the following purposes:

Carrying out the execution, maintenance, compliance and control of the contractual relationship, which may include authenticating the user's identity and/or sending access keys to allow access and use of the service, as well as any purposes directly or indirectly related to the use of such services through this website, all without prejudice to this information being specifically indicated in the particular contracting conditions and in the data request forms used for such purposes. Send the user by postal mail, email and other equivalent electronic communication means newsletters, news, invitations to events, commercial and advertising communications regarding VBOTE products or services similar to those initially contracted, as long as the user does not object to such processing of their data for promotional purposes through the free procedure provided for this purpose by VBOTE both at the time of registration and in each commercial communication sent to you.

On the legal basis of legitimate interest, VBOTE may carry out the processing of the user's data for the following purposes:

Exclusion from sending commercial and advertising communications: When the user requests deletion from the service of sending commercial and advertising communications, VBOTE will process their data to retain the minimum essential data of the interested party, for the purpose of identifying them and adopting the necessary measures to prevent the sending of commercial and advertising communications.

In any case, the user is informed that the purposes for processing user data collected through the forms published on the site will be explained through informative texts published in the forms themselves and when required, as stated above, VBOTE will request, through the appropriate boxes, the user's consent for the processing of their personal data when the legal basis for such processing is based on obtaining the user's consent.

9. Recipients of data

On the legal basis of compliance with legal obligations, the user's personal data will be communicated to third parties when there is a legal obligation to communicate to the competent public authorities for reasons of the matter and/or to attend to requests made by them.

In such cases, potential recipients of the data may be, without limitation, administrative bodies or Control Authorities in matters of data protection, telecommunications and information society, Judges, Public Prosecutor's Office, Courts, Court of Auditors or Ombudsman.

On the legal basis of the execution of a contractual obligation, in case the user activates, registers or contracts a service offered through the website, VBOTE may transfer their data to third parties necessarily involved in the management of the service for the purpose of properly managing the entire activation, subscription or contracting process of the service, and recipients of their data may be banking and financial service entities involved in the collection of services, and any other third parties that necessarily, directly or indirectly, must intervene in the management of the contracting of the service.

VBOTE informs the user that any other communication of data to third party recipients that it must make will be brought to your attention by informing you expressly, precisely and unequivocally of the legal basis for processing, the recipients of the information, the purpose for which the data will be used, and the nature of the data transferred and, where appropriate, when legislation so provides, the user's explicit, unequivocal, specific and informed consent will be requested in advance. For these purposes, the user must pay special attention to the basic and detailed or additional information provided to you in each case in the personal data collection forms published on the site.

In cases where, in accordance with what is indicated in this section, VBOTE communicates data to a third party, VBOTE is not responsible for the processing of the data carried out by that third party, who, in any case, will become the new person responsible for processing the information, being obliged to comply with the obligations that, for this purpose, current regulations establish.

Additionally, third-party service providers with the status of data processors may be recipients of the data for the purpose of providing services that support data processing tasks, always at VBOTE's request and following the subscription of a data processing service agreement with sufficient guarantees of security, confidentiality, return or destruction of data and compliance with the instructions given by VBOTE to carry out processing. These include the following categories of companies providing web hosting services, service providers for sending communications, providers of computer maintenance and support services and others.

10. International transfers of data

Except as required by law, VBOTE will not carry out international transfers of the user's personal data to either countries or international organizations.

11. Period of retention of personal data

Regarding the retention periods of the data supplied by the interested party through the site, the following retention criteria will be applied depending on the purposes for which they have been supplied:

Personal data that has been provided by the interested party to contact VBOTE and request information will be retained by VBOTE while the processing is maintained and as long as the interested party does not request its deletion and, where appropriate, until the legal deadlines for compliance with obligations and attention to possible liabilities are completed.

When the interested party has expressly authorized the sending of advertising information, the data will be retained by VBOTE while the processing is maintained and as long as the interested party does not request its deletion and, once deletion of the data is requested by the interested party, and, where appropriate, until the legal deadlines for compliance with obligations and attention to possible liabilities are completed.

When the interested party sends their curriculum vitae to VBOTE, the data will be retained by this entity for a period of 24 months from receipt, unless the interested party requests its deletion before that deadline expires and, where appropriate, until the legal deadlines for compliance with obligations and attention to possible liabilities are completed.

Personal data that has been provided by the interested party for activation, subscription or contracting of a service will be retained by VBOTE while the contractual relationship is in force and, once this purpose has ended or deletion of the data is requested by the interested party and, where appropriate, until the legal deadlines for compliance with obligations and attention to possible liabilities are completed.

12. Exercise of rights

The user has the right to request from VBOTE access to their personal data, its rectification, deletion, limitation of processing, opposition and portability.

You also have the right to withdraw the consent granted for processing at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.

For the exercise of any of these rights, you must send a written request to VBOTE INNOVATION S.L., to the following postal address: Calle Pascual y Genís, 20 4º pta.5 - 46002 Valencia, or electronically to: info@tweem.com.

13. Protection of user rights

In any case, the user is informed of the right to file a complaint with the Spanish Data Protection Authority (AEPD), in particular, when the user considers that they have not obtained satisfaction from VBOTE in the exercise of their rights.

The user can contact the AEPD through www.aepd.es or at the following address: C/ Jorge Juan, 6. 28001 - Madrid, and/or contact telephone 912 663 517.

14. Other user rights in electronic commerce and electronic commercial communications

VBOTE informs the user who has expressly authorized the sending of commercial advertising communications, newsletters, news and invitations to events by electronic means that, under Articles 21 and 22 of the Law on Information Society Services and Electronic Commerce (LSSICE), the user has the right to object to the processing of their data for promotional purposes for the receipt of commercial advertising communications and advertising, as well as the right to revoke at any time the consent granted for this purpose with simple notification of their will to VBOTE and/or by sending an email with the subject UNSUBSCRIBE.

To do this, the user may direct their communication requesting the cessation of sending commercial advertising communications by revocation of consent and/or opposition to the email address: info@tweem.com requesting it and/or indicating UNSUBSCRIBE in the subject.

VBOTE will attend to your request by retaining the minimum essential data to take the necessary measures to prevent the sending of such commercial communications.

15. Information society service providers and other third parties

VBOTE warns the user that this entity is solely responsible and guarantees the confidentiality, security and treatment of data in accordance with this policy, regarding personal data that it collects from the user through this website, having no responsibility whatsoever regarding the processing and subsequent use of personal data that could be carried out by third-party information society service providers who could access such data by reason of the provision of their services or exercise of their activity.

Third-party information society service providers shall be understood -without limitation- as those natural or legal persons who provide the following services: (i) Transmission through a communication network of data provided by service recipients. (ii) Services for access to the aforementioned network. (iii) Data storage or hosting services. (iv) Supply of contents or information.

VBOTE is not responsible for the processing of data carried out by third parties who establish hyperlinks with VBOTE nor those carried out by those responsible (private companies and/or public administrations) mentioned on the www.tweem.com site and whose websites are accessible through the corresponding links that may be published on the www.tweem.com website.

16. Follow us on social networks

Social networks are services provided by third-party providers that allow the user to participate in a virtual community with other users through which they can generate their own public profile to create and share content, information and personal data with other network users. In a social network you can create and share pages, accounts or profiles for personal and/or commercial purposes. The functioning of the social network is regulated in the first place, by the conditions established by the owner and/or provider of the network and in the second place, when it comes to pages, accounts or profiles for commercial purposes, by the terms and conditions established by the person responsible for the commercial profile or account who will also be responsible for the processing of the data.

VBOTE has TWEEM profiles on some social networks which are linked and accessible to the user, through the corresponding icons and links published on the site. You can follow us and become a fan of the official pages of VBOTE and TWEEM on the mentioned social networks.

The user is informed that the processing of data carried out through the pages, profiles or accounts of VBOTE and TWEEM on social networks will be governed by the corresponding policies and conditions of both the official page and the provider and owner of each social network, where applicable, with this owner and social network provider also being responsible for the file of personal data of users who are treated on the official page.

17. Personal data published on the website

In relation to personal data that may be published on the website www.tweem.com, the user is informed that such data are part of one or several data processing operations owned and managed by the aforementioned entity in which they have been incorporated with the prior informed consent of those concerned and cannot be freely processed and reproduced by the user or other third-party users -not even when reference is made to their origin- unless prior authorization and informed consent of the person concerned is obtained.

The personal data that VBOTE may publish on its website www.tweem.com could consist, without limitation, of any numerical, alphabetical, graphic, photographic, acoustic or any other type of information concerning identified or identifiable natural persons, such as name, surnames, photos, images of events held by the entity, data published by users of web services and other information.

Therefore, all personal data -including images, videos, texts, data and any other information published on our website www.tweem.com about identified and/or identifiable natural persons- may only be used by the user for the purpose of participating and enjoying our website in the manner established in this policy, or in the case of particular conditions that regulate a certain service, for private purposes and within the framework of current law and without profit motive or commercial purposes of any kind, with any other uses different from those indicated being expressly prohibited, including the incorporation of images or data into files or processing and/or creation of databases of people and/or sending advertising or transfer to third parties, without the prior informed consent of the user who is the owner of the information and data, VBOTE not being responsible for the uses that the user or other third-party users of our website make in violation of what is established in these conditions and others that regulate them.

Under no circumstances should the user consider that the website www.tweem.com of VBOTE is a source accessible to the public from which free disposal can be made of the personal data, information and content published through it.

18. Security measures

VBOTE informs the user that, in accordance with the provisions of data protection legislation and taking into account the state of the art, application costs, and the nature, scope, context and purposes of processing, as well as risks of varying probability and severity to the rights and freedoms of natural persons that data processing entails, it has adopted the technical and organizational measures necessary to ensure an appropriate level of security for the risk and prevent accidental or unlawful destruction, loss or alteration of data as well as unauthorized processing, retention, communication or access to such data.

VBOTE will regularly verify, evaluate and audit the effectiveness of such measures, updating them where necessary in accordance with the results of such evaluations.

Likewise, VBOTE guarantees the user's compliance with the duty of professional secrecy regarding the personal data of users and the duty to keep them.

19. Use of cookies and data storage and retrieval devices on user terminal equipment

VBOTE uses cookies and data storage and retrieval devices on user terminal equipment when the user browses the www.tweem.com site.

Such cookies and data storage and retrieval devices are used by VBOTE under the conditions described in its Cookie Policy.

20. Recommendations to users

VBOTE recommends users to use the latest versions of computer programs for their Internet browsing given the incorporation of greater security measures in them.

Likewise, VBOTE recommends users to use the security mechanisms at their disposal (secure web servers, cryptography, digital signature, firewall, etc.) to protect the confidentiality and integrity of their data to the extent necessary, given that there are risks of identity spoofing or communication violation.

VBOTE reminds users that Internet is not secure. However, there are and are being developed different means that allow you to improve the protection of your data. Therefore, use any means at your disposal to protect your data and communications, such as legally available encoding for confidential email and access codes to your own PC.

VBOTE warns users that whenever they provide personal information over the Internet through email, newsgroups, discussion forums, etc., they should bear in mind that such information may be collected and processed for purposes not desired by users, so VBOTE recommends that users inform themselves about the confidentiality and privacy policies of online sites they visit.

VBOTE warns users to bear in mind that, unless they use encryption mechanisms, email on the Internet is not secure. Email messages and discussion forums may be subject to forgery and identity spoofing, which must be taken into account whenever they are used. If they do not want to publish their email address, they should configure their browser so that it does not leave their email address on the web servers they access.

21. Update of policies

Without prejudice to the preferential application of the specific legal texts to this effect such as informative texts contained in data collection forms published by VBOTE on www.tweem.com, as well as, where appropriate, in the conditions of particular services, VBOTE will periodically update this privacy policy and processing of personal data of website users. Any modification of this policy will be published on the www.tweem.com website, taking into account each user that, the processing of personal data that they may communicate to VBOTE will be governed by the rules established and in force at the time of such communication.

In any case, it will be the user's responsibility to periodically access the privacy policies published by VBOTE in order to know the latest version at all times.

22. Contact information