Privacy Policy

1. Controller of personal data

  • Name: JOTELULU, S.L. (hereinafter, <<JOTELULU>>).
     
  • Registered office: Impact Hub Picasso, plaza Pablo Ruiz Picasso, n.º 1, 28020 Madrid, Spain.
     
  • Tax ID: B-65814709.
     
  • Register details: Barcelona Trade Register, volume 43288, folio 0129, section: 8, page: B 423241, entry 1.
     
We inform that the website www.jotelulu.com owned by JOTELULU (hereinafter, <<JOTELULU>>), complies with the guidelines of the current regulations on the protection of personal data, Regulation (EU) 2016/679 of 27 April 2016 (RGPD) as well as the LO 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, regulations on the protection of natural persons with regard to the processing of personal data and the free movement of this data.

2. Processing principles

In the processing of personal data, we will apply the following principles that comply with the requirements of the Personal Data Protection Legislation:
 
  • Principle of lawfulness, fairness, and transparency: we will require consent for the processing of your personal data for one or more specific purposes of which we will inform you in advance with absolute transparency.
     
  • Principle of data minimisation: we will only request data that is strictly necessary in relation to the purposes for which it is required.
     
  • Principle of limitation of the storage period: the data will be kept for no longer than is necessary for the purposes of the processing, depending on the purpose, we will inform you of the corresponding storage period.
     
  • Principle of integrity and confidentiality: data will be processed in such a way as to ensure adequate security of personal data and guarantee confidentiality.
     

3. Data requested and purpose of processing

As a User, you are solely responsible for the veracity and correctness of the data that you send us directly or through the Website, exonerating us from any responsibility for them. At JOTELULU we are responsible for the collection, processing, and use of the personal data that you provide us with through the registration or contact forms that are included on the Website and the JOTELULU Platform or in any communications between the User and JOTELULU according to data protection legislation. In this regard, we inform you that the data you voluntarily provide us with are collected and processed for the following purposes:
 
  1. Visitors of the website
Categories of data Legal basis
You can visit the Website without revealing your identity. However, your browser only sends information - which is automatically collected - to our website’s servers. This information is temporarily stored in a log file. This information is automatically collected and stored until it is automatically deleted:
  • IP address of the requesting computer
  • Date and time of access
Consent of the data subject
 
These data are collected and processed to enable the use of our website (connection establishment), to ensure the security and stability of our system as well as for the technical administration of the network infrastructure.
 
  1. Clients
Categories of data
Legal basis
Those necessary for the maintenance of the commercial relationship. Invoicing, sending postal or e-mail advertising, after-sales service, and customer loyalty: (i) identification data: name and surname, e-mail address; (ii) personal characteristics: country of residence.
Contractual relationship between the parties
Those necessary for sending commercial communications by electronic means.
Consent of the data subject
 
  1. Subscription form
Categories of data
Legal basis
To receive newsletters or posts from our blog, we must first obtain your express and specific consent for this purpose. We obtain this consent when you register to the blog and explicitly request to receive posts by entering your email address.
Consent of the data subject
 
  1. User Profile
Categories of data
Legal basis
On our Website and Platform we offer IT and Communications Products. To use and manage these Products, users must first register. By registering on the Platform, you provide us with the following information: i) Email address, ii) User's first and last name, iii) Company name and details, iv) Payment method.
Consent of the data subject and contractual relationship between the parties.
 
  1. Service Providers
Categories of data
Legal basis
Those necessary to carry out the corresponding transactions, invoicing, and the declaration of the appropriate taxes. (i) identification data: name and surname, e-mail address; (ii) tax and bank details: for direct debit of payments.
Contractual relationship between the parties
Those necessary for sending commercial communications by electronic means.
Consent of the data subject.
 
  1. Employees
Categories of data
Legal basis
Those necessary to maintain the employment relationship, pay the necessary taxes and register with the Social Security: (i) identification data: name and surname, e-mail address; (ii) fiscal and banking data: for direct debit of payments.
Contractual relationship between the parties.
 
  1. Social media followers
Categories of data
Legal basis
Those necessary to engage with you and create community.
That granted to the social network in question. The conditions of use, privacy policies and access regulations that belong to the social network that applies in each case and have been previously accepted as a user will apply.
 
  1. Referral Program
 
Categories of data
Legal basis
The contact details (name, email, telephone number) of the referrals.
Consent of the data subject.
 
  1. Partner’s Program
 
Categories of data
Legal basis
The contact details (name, email, telephone) of the Partners, as well as the financial details necessary for invoicing (payment method).
Consent of the data subject and execution of a contract.

4. Consent

By entering the data, as a User you give your express and unequivocal consent, declaring that you have been informed of the conditions on the protection of personal data, accepting and consenting to the automated processing of the same, so that we can proceed to process the data provided for the aforementioned purposes. It also implies consent to the international transfer of data, due exclusively to the fact that some of the suppliers or third parties that provide services necessary for the development of this website are located in other countries.
 
Failure to provide the personal data requested and not accepting this data protection policy (<<checkbox>> in the form) means the impossibility of managing the services (purposes) mentioned above.

5. Minors

Minors under 16 years of age are expressly mentioned in relation to the processing of their personal data. Minors may not access this Website without the consent of their parents or guardians. In this regard, JOTELULU shall not be held responsible for any failure to comply with this provision.

 

6. Third party data

At JOTELULU we only process the data provided to us by the data subjects. If you provide us with data of third parties, you must previously inform and request their consent, or else you exempt us from any liability for failure to comply with this requirement.

7. Data Processors

JOTELULU informs you that we will not transfer personal data to third parties, except by legal obligation. However, in the case of transfer to a third party, we will inform you beforehand and ask for your consent.
 
In order to provide the requested services, JOTELULU may disclose personal data to its service providers (e.g., hosting services, site maintenance and security, billing, etc.). Some of these service providers have their servers located in foreign countries. By means of this policy we would like to mention that we proceed to carry out (in such cases) the international transfers permitted in order to carry out the service/functionality that you have requested, safeguarding at all times the security of your data and ensuring that they comply with the data protection requirements contained in the RGPD, imposing the necessary confidentiality measures and other necessary technical-organisational measures. Such guarantees and safeguards consist of adequacy decisions of the European Commission, standard contractual clauses approved by the European Commission or other legal mechanisms permitted by the GDPR.
 
In case JOTELULU does not act as a Data Controller but as a Data Processor, personal data will be processed in accordance with the Data Processing Agreement found at the following link: [link], concluded between JOTELULU and the customer/User.

8. Derechos reconocidos

JOTELULU guarantees you as a User the exercise of your rights of access, rectification, cancellation, information and opposition, limitation, and portability, under the terms set out in current legislation. Therefore, you may exercise your rights by sending an express request to the postal address indicated in the heading and/or by sending an email to dpd@jotelulu.com, indicating in the subject: ARCO-POL Rights, and attaching a photocopy of your ID card. If required, we have at your disposal forms for the correct exercise of your rights. We proceed to detail what each of these rights consist of:
 
  • Right of access: allows you to know and obtain information about your personal data subject to processing.
     
  • Right of rectification: allows you to correct errors, modify data that proves to be inaccurate or incomplete and ensure the accuracy of the information undergoing processing.
     
  • Right of erasure: allows you to request the deletion of the data undergoing processing when they are no longer necessary for the execution or provision of the service.
     
  • Right of opposition: this allows you to prevent the processing of your personal data from being carried out, except for legitimate reasons or for the exercise or defence of possible claims, in which case we will keep them blocked for the corresponding period of time while the legal obligations persist.
     
  • Limitation of processing: allows you to request the limitation of the processing of your data, in which case they will only be kept for the exercise or defence of claims.
     
  • Data portability: this allows you to request the sending of the data concerning you that you have provided to us to another data controller that you indicate (provided that this is technically possible).
     
  • Right not to be subject to automated individual decisions (including profiling): the right not to be subject to a decision based on automated processing that produces effects or significantly affects you.
     
 
In the event of acting as a representative of the holder of the personal data (data subject), it will be necessary for you to provide proof of such representation by means of your ID card or electronic signature.
 
In turn, as a User, you have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the lawfulness of the processing carried out prior to the withdrawal of consent. Further information is available at the following link: https://www.aepd.es/es/derechos-y-deberes/conoce-tus-derechos.
 
You also have the right to lodge a complaint with the supervisory authority if you consider that your rights in relation to the protection of your data may have been infringed before the Spanish Data Protection Agency (AEPD), at Calle Jorge Juan, 6, 28001-Madrid or through the link to the AEPD's website: https://sedeagpd.gob.es/sede-electronica-web/.

 

9. Security of the data

JOTELULU undertakes to implement the legally required security measures that are appropriate to the state of technology, in order to ensure the confidentiality, availability and integrity of the information hosted on its servers. However, we must remind you that there is no invulnerable technology and that you must therefore use the means at your disposal to maintain the level of security of your data. We especially recommend that you use strong passwords to access your User account, with at least 8 characters alternating numbers, letters, uppercase, lowercase and special characters. We also recommend that you change your password regularly (at least once a year) and that if you suspect that a third party may know your password, you change it immediately.
 
The personal data collected is stored in a secure environment within the EU and is treated confidentially. Access to this information is limited to selected employees and suppliers of JOTELULU.

10. Duration of processing

The data you have provided to us will be kept for as long as there is a mutual interest in maintaining the purpose of the processing and/or for the period of time for which legal liabilities may arise from the services provided. When it is no longer necessary for that purpose, it will be deleted with appropriate security measures to ensure pseudonymisation of the data or complete destruction of the data. If required, we have a table with the specific period of duration of each of the processing carried out.

11. Additional notes

JOTELULU reserves the right to modify this policy to adapt it to new legislation or jurisprudence.
 
For any aspect related to this privacy policy, you can contact JOTELULU at the e-mail address shown in the heading.