Privacy Policy

This privacy policy outlines how personal data will be managed on this website. It is essential that you read and accept it before continuing to browse.

**Responsible Party Details**

Among the values we identify with is transparency, which is why we want you to know from the start that your data privacy is very important to us. This privacy statement explains what personal data we collect from our users and how we use it. We invite you to read these terms carefully before providing your personal data on this website.

On this website, the personal data of users is respected and protected. As a user, you should know that your rights are guaranteed.

We have strived to create a safe and reliable space, and for this reason, we want to share our principles regarding your privacy:

- We never request personal information unless it is truly necessary to provide the services you request.

- We never share our users' personal information with anyone, except to comply with the law or with your express authorization.

- We never use your personal data for any purpose other than that stated in this privacy policy.

Please note that this Privacy Policy may vary depending on legislative or self-regulation requirements, so users are advised to visit it periodically. It will be applicable if users decide to fill in any form on this website where personal data is collected.

UNDERLOCK.ES has adapted this website to comply with the requirements of Organic Law 15/1999, of December 13, on the Protection of Personal Data (LOPD), and Royal Decree 1720/2007, of December 21, known as the LOPD Development Regulation. It also complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, regarding the protection of individuals (GDPR), as well as Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSICE or LSSI).

For the purposes of the General Data Protection Regulation mentioned above, the personal data you send through the website forms will receive the treatment of "Website Users".

To process our users' data, we implement all the technical and organizational security measures established in the current legislation.

**Principles we will apply to your personal information**

In the processing of your personal data, we will apply the following principles that comply with the requirements of the new European data protection regulation:

- **Principle of lawfulness, fairness, and transparency:** We will always require your consent for the processing of your personal data for one or more specific purposes that we will inform you about in advance with absolute transparency.

- **Data minimization principle:** We will only request data that is strictly necessary in relation to the purposes for which we require it. The minimum possible.

- **Principle of limitation of the retention period:** Data will be maintained for no longer than necessary for the purposes of the processing. Depending on the purpose, we will inform you of the corresponding retention period, in the case of subscriptions, we will periodically review our lists and delete those records that have been inactive for a considerable time.

- **Principle of integrity and confidentiality:** Your data will be treated in such a way as to ensure adequate security of personal data and guarantee confidentiality. You should know that we take all necessary precautions to prevent unauthorized access or misuse of our users' data by third parties.

**How did we obtain your data?**

The personal data we process at UNDERLOCK.ES comes from:

- Contact form

**What are your rights when you provide us with your data?**

Any person has the right to obtain confirmation on whether UNDERLOCK.ES is processing personal data concerning them or not.

Interested persons have the right to:

- Request access to personal data concerning the data subject

- Request rectification or erasure

- Request the limitation of their processing

- Object to processing

- Request data portability

Data subjects may access their personal data and request the rectification of inaccurate data or, where appropriate, request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected. In certain circumstances, data subjects may request the limitation of the processing of their data, in which case we will only retain them for the exercise or defense of claims.

In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. UNDERLOCK.ES will stop processing the data, except for compelling legitimate reasons or the exercise or defense of possible claims. As a data subject, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit them to another data controller when:

- The processing is based on consent

- The data has been provided by the data subject

- The processing is carried out by automated means

When exercising your right to data portability, you will have the right to have the personal data transmitted directly from controller to controller where technically feasible.

Data subjects will also have the right to effective judicial protection and to file a complaint with the supervisory authority, in this case, the Spanish Data Protection Agency, if they consider that the processing of personal data concerning them infringes the Regulation.

**For what purposes do we process your personal data?**

When a user connects to this website, for example, to send an email, they are providing personal information for which UNDERLOCK.ES is responsible. This information may include personal data such as your IP address, name, physical address, email address, phone number, and other information. By providing this information, the user gives their consent for their information to be collected, used, managed, and stored by UNDERLOCK.ES, only as described in the Legal Notice and this Privacy Policy.

At UNDERLOCK.ES, there are different systems for capturing personal information, and we process the information provided by interested persons for the following purpose for each information capture system (forms):

- **Contact form:** We request the following personal data: Name, Email, and phone number to respond to the users of UNDERLOCK.ES. For example, we can use these data to respond to your request and answer any questions, complaints, comments, or concerns you may have regarding the information included on the website, the services provided through the website, the processing of your personal data, questions regarding the legal texts included on the website, as well as any other queries you may have that are not subject to the terms of the contract. I inform you that the data you provide will be located on the servers of OVH.

There are other purposes for which we process your personal data:

- To ensure compliance with the conditions of use and the applicable law. This may include the development of tools and algorithms that help this website ensure the confidentiality of the personal data it collects.

- To support and improve the services offered by this website.

- Other non-identifying data obtained through some cookies that are downloaded to the user's computer when browsing this website, which I detail in the cookies policy.

- To manage social networks. UNDERLOCK.ES has a presence on social networks. The processing of data carried out by the people who become followers on the social networks of the official pages of UNDERLOCK.ES, will be governed by this section. As well as by those conditions of use, privacy policies, and access regulations that belong to the social network that applies in each case and previously accepted by the user of UNDERLOCK.ES. Your data will be processed with the purposes of correctly managing your presence on the social network, informing you of activities, products, or services of UNDERLOCK.ES. As well as for any other purpose that social networks allow. In no case will we use the profiles of followers on social networks to send advertising individually.

According to the provisions of the General Data Protection Regulation (GDPR) 2016/679, UNDERLOCK.ES, with an address at Segorbe 8, Bajo Izquierda, 46004, Valencia, will be responsible for the processing of the data corresponding to website users and subscribers.

UNDERLOCK.ES does not sell, rent, or transfer personal data that can identify the user, nor will it in the future, to third parties without prior consent. However, in some cases, collaborations with other professionals may be made, in such cases, consent will be required from users informing about the identity of the collaborator and the purpose of the collaboration. It will always be carried out with the strictest security standards.

**Remarketing**

The remarketing function allows us to reach people who have visited UNDERLOCK.ES previously and associate a specific audience with a particular message. Remarketing is a method to get users who have visited our site to return.

As a user of UNDERLOCK.ES, we inform you that we reserve the right to collect information for this remarketing function.

The information we collect thanks to this function is collected by Facebook cookies. You can learn about the data these cookies collect in the privacy policies of each service:

- Facebook

If you do not want your information to be collected by these cookies, you can disable the use of Google cookies through Google Ads Settings. You can also disable the use of cookies from a third-party vendor through the Network Advertising Initiative opt-out page.

This type of service allows interaction with social networks or other external platforms directly from the pages of this website. The interactions and information obtained by this website will always be subject to the user's privacy settings in each social network. If a service that allows interaction with social networks is installed, it is possible that

, even if users do not use the service, it collects web traffic data related to the pages where they are installed.

**Legitimacy for the processing of your data**

The legal basis for the processing of your data is consent. To contact or make comments on this website, consent to this privacy policy is required.

**Data category**

The data categories processed are identifying data.

**How long will we keep your data?**

The personal data provided will be kept:

- As long as the commercial relationship is maintained.

- Until its deletion is requested by the interested party.

**To which recipients will your data be communicated?**

Many tools we use to manage your data are contracted out to third parties. To provide services strictly necessary for the development of the activity, UNDERLOCK.ES shares data with the following providers under their corresponding privacy conditions:

- Google Analytics: a web analytics service provided by Google, Inc., a Delaware company whose main office is at 1600 Amphitheatre Parkway, Mountain View (California), CA 94043, United States (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help UNDERLOCK.ES analyze how users use the website. The information generated by the cookie about your use of UNDERLOCK.ES (including your IP address) will be transmitted to and stored by Google on servers in the United States.

- Hosting: OVH, domiciled in Spain. More information at: https://www.ovh.es/ OVH processes the data in order to perform its hosting services to UNDERLOCK.ES.

**Browsing**

When browsing UNDERLOCK.ES, non-identifiable data may be collected, which may include IP addresses, geographical location (approximate), a record of how services and sites are used, and other data that cannot be used to identify the user. Among the non-identifiable data are also those related to your browsing habits through third-party services. This website uses the following third-party analysis services:

- Google Analytics

We use this information to analyze trends, administer the site, track users' movements around the site, and gather demographic information about our user base as a whole.

**Data secrecy and security**

UNDERLOCK.ES is committed to the use and processing of users' personal data, respecting their confidentiality and using them in accordance with the purpose thereof, as well as to complying with its obligation to save them and adapt all measures to prevent alteration, loss, processing or unauthorized access, in accordance with the provisions of current data protection regulations.

This website includes an SSL certificate. It is a security protocol that makes your data travel integrally and securely; that is, the transmission of data between a server and a web user, and in feedback, is fully encrypted or coded.

UNDERLOCK.ES cannot guarantee the absolute impregnability of the internet network and therefore the violation of the data through fraudulent access by third parties.

With respect to the confidentiality of the processing, UNDERLOCK.ES will ensure that any person who is authorized by UNDERLOCK.ES to process the client's data (including its staff, collaborators, and providers), will be under the appropriate obligation of confidentiality (whether a contractual or legal duty).

When a security incident occurs, upon realizing UNDERLOCK.ES, it shall notify the Client without undue delay and shall provide timely information related to the Security Incident as it is known or when the Client reasonably requests it.

**Accuracy and veracity of data**

As a user, you are solely responsible for the veracity and correctness of the data you send to UNDERLOCK.ES, exonerating UNDERLOCK.ES of any responsibility in this regard. Users guarantee and are responsible, in any case, for the accuracy, validity, and authenticity of the personal data provided, and they commit to keeping them duly updated. The user agrees to provide complete and correct information in the contact form or subscription form.

**Acceptance and Consent**

The user declares to have been informed of the conditions regarding the protection of personal data, accepting and consenting to the processing thereof by UNDERLOCK.ES in the manner and for the purposes indicated in this privacy policy.

**Revocability**

The consent given, both for the processing and for the transfer of the data of the interested parties, can be revoked at any time by notifying UNDERLOCK.ES in the terms established in this Policy for the exercise of ARCO rights (Access, Rectification, Cancellation, and Opposition). This revocation will in no case be retroactive.

**Changes in the privacy policy**

UNDERLOCK.ES reserves the right to modify this policy to adapt it to new legislation or jurisprudence, as well as to industry practices. In such cases, the Provider will announce on this page the changes introduced reasonably in advance of their implementation.

**Commercial emails**

According to the LSSICE, UNDERLOCK.ES does not engage in SPAM practices, and therefore does not send commercial emails that have not been previously requested or authorized by the user. Consequently, on each of the forms on the website, the user has the possibility to give their express consent to receive the newsletter, regardless of the commercial information promptly requested.

In accordance with the provisions of Law 34/2002 on Information Society Services and Electronic Commerce, UNDERLOCK.ES undertakes not to send communications of a commercial nature without properly identifying them.