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PRIVACY POLICY

BASIC INFORMATION ON DATA PROTECTION

Controller

HTP DIGITAL WAY SERVICES SL

CIF: B67694091

Calle Velázquez, 64, 28001, Madrid

support@htpdigiwayservices.com

Purpose

1. Managing the contracting of the products as well as executing mobile payment services authorized by the user in the contracting of the products

2. Sending electronic commercial communications

Legitimacy

1. Execution of the contractual relationship

2. Legitimate interest

Recipients

Data may be accessible to our service providers in order to duly execute the required services, as well as to certain Administrations due to legal obligations.

Data may be communicated to Group entities for administrative purposes.

Rights

You have the right of access, rectification, deletion, opposition, processing limitation and data portability.

 

DETAILED INFORMATION ON DATA PROTECTION

1. IDENTIFICATION

  • Controller: HTP DIGITAL WAY SERVICES SL (hereinafter, “HDWS” “Controller”or “we”)
  • CIF (Tax ID number): B67694091
  • Company registered office: Calle Velázquez, 64, 28001, Madrid.
  • Contact Email: support@htpdigiwayservices.com
  • Data Protection Officer (DPO): privacy@mobileawareservices.com

2. INFORMATION AND CONSENT

HDWS commits to observe your privacy and ensure the protection and security of your personal data. Therefore, we inform you about the way in which we collect, process and protect the personal data that you provide to us.

Consequently, you need to read carefully this privacy policy which has been written in a clear and simple way so as to enable you to understand it and thus decide freely and voluntarily if you wish to provide your personal data to HDWS.

3. OBLIGATION OF DATA PROVISION

The data requested in the forms provided on the website are, in general, mandatory (unless specified otherwise in the required field) for accomplishment of the established purpose. To the contrary, however, the result may be the impossibility to provide the service to the user.

4. WITH WHAT PURPOSE WILL THE COMPANY PROCESS THE USER’S PERSONAL DATA?

Your collected personal data will be processed by HDWS in conformity with the following purposes:

  • Managing the contracting of the products.
  • Managing subscription plans.
  • Performing mobile payment services authorized by the User.
  • Managing, conducting and giving answers to the petitions, demands, incidences, complaints, claims or users’ consultations, as well as managing the refunds.
  • Maintenance, support and updating of the website. Resolution of possible technical incidents or of those of any other nature that may arise in relation to the website.
  • Draw-up of anonymous statistical reports on access habits and the activity developed by users on the website.

5. WHAT DATA WILL WE PROCESS?

We will be processing the data that we will seek from you and, in any case, those indicated as mandatory for the provision of the services, such as among others:

  • Identification data, such as name and surname, address, telephone number, email address.
  • Location data through IPs, such as browser, device and operating system.

 

6. WHAT IS THE LEGITIMACY OF DATA PROCESSING?

The legitimacy for processing of the data will be:

  • Execution of a contract for:
    • The purchasing and the provision of the services. Where appropriate, for the request and management of reimbursements.
  • User’s consent to:
    • Management of queries, requests for information, complaints and claims, receiving relevant information.
    • Sending communications for marketing purposes.
  • Legitimate interest of the controller in:
    • Draw-up of anonymous statistical reports.
    • Sending communications for marketing purposes related to products and services of HDWS to our customers.

When consent is given for the processing of your personal data you may revoke it at any time provided such consent shall not affect the lawfulness of the processing previously carried.

To revoke consent, the user may contact the controller through the following email: privacy@mobileawareservices.com

7. WHO THE DATA WILL BE SHARED WITH?

User’s data may be communicated to:

  • The Controller suppliers with the aim of duly providing the services purchased. Suppliers will not process your data for their own purposes.
  • Data may be communicated to Group entities for administrative purposes.
  • Public administrations, in relation to the competences attributed to them.

8. FOR HOW LONG WILL WE KEEP USER’S DATA?

The data will be processed during the time necessary to accomplish the indicated purposes, differentiating between the data necessary for the provision of the purchased products, of those processed for marketing purposes or customer service, unless the user requests the withdrawal, opposes or revokes consent.

9. RESPONSIBILITY OF THE USER

The user:

  • Guarantees that his/her age is over 18 and that the data provided to the Controller are true, accurate, complete and up-to-date. For these purposes, the user is responsible for the truthfulness of all communicated data, and will keep the provided information updated so as to reflect his/her real situation.
  • In the event that the user provides data of third parties, he / she declares to have their consent and undertakes to transfer the information contained in the Privacy Policy to the interested party, owner of said data, exempting the Controller from any responsibility in this regard. However, the Controller may carry out the necessary actions to verify this fact, adopting the appropriate due diligence measures, in accordance with current regulations on data protection.
  • Will be responsible for false or inaccurate information provided through the website and for damages, direct or indirect, inflicted to HDWS or to third parties thereby.

10. EXERCISE OF RIGHTS

The following rights may be exercised, at any time and free of charge, by sending an email to privacy@mobileawareservices.com attaching a copy of the identity document:

  • Revoke the granted consent.
  • Access your personal data.
  • Rectify inaccurate or incomplete data.
  • Request deletion of your data when, among other reasons, the data are no longer necessary for the purposes they were collected for.
  • Obtain from the Controller the limitation of the data processing.
  • Obtain human intervention, to express your point of view and to challenge the automated decisions adopted by the Controller, in the cases foreseen in the regulations.
  • Seek portability of your data in the cases envisaged in the regulations.

In addition, you may file a complaint regarding the protection of your personal data with the Spanish Data Protection Agency at the address Calle de Jorge Juan, 6, 28001, Madrid,

11. SECURITY MEASURES

HDWS will process your data at all times in an absolutely confidential manner and keeping the secret thereof, in accordance with the provisions of the applicable regulations, adopting the necessary technical-organizational measures to ensure the security of your data and helping to avoid their alteration, loss, processing or unauthorized access, taking into account the state of the technology, the nature of stored data and the inherent risks.