PRIVACY POLICY
In this policy you will find all the information regarding the processing of your personal data and the rights you can exercise to maintain control over them. Therefore, you should read it carefully before using any of our services. Please do not hesitate to contact us with any questions you may have in this regard.

MAIN QUESTIONS ABOUT THE PROCESSING OF YOUR PERSONAL DATA
LULLAAI NETWORKS, S.L. (from now on “LULLAAI”), as Data Controller, we need to have the personal data we ask you for during your navigation and use of the website: https://lullaai.com/es/ (from now on “Website”) or the mobile application (from now on “App”), with the purpose of:

ü  Offering you different channels to contact us, to ask for information, to solve doubts, etc.

ü  Processing your registration as a LULLAAI user so that you can use our digital sleep assistant and other features that we make available through our App.

ü  Providing you with personalised advice regarding your baby’s sleep in cases where you wish to place yourself in the hands of our specialists.

ü  Offering you, where appropriate, products and services that may be of interest to you.

ü  helping improve the development, maintenance and usability of the Website.

In any case, we guarantee to keep this information with the maximum guarantees of security and in accordance with current regulations on personal data protection.

you can exercise your rights at any time under the data protection regulations or ask us any questions you may have about the processing of your data by contacting us by e-mail at contact@lullaai.com. [E1] 

FULL TEXT OF THE PRIVACY POLICY
1.    WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
Your personal data will be processed by the company LULLAAI NETWORKS, S.L. (“LULLAAI”), the Data Controller, with tax identification number B88293097 and whose contact details are as follows:

·       Address: C/ Bahía de Almería, 34 1C 28042 Madrid

·       Contact telephone number:

·       Contact email: contact@lullaai.com. 

1.1. Our Data Protection Officer: Here you can find the contact details of our Data Protection Officer, to whom you can address any queries you may have in relation to this Privacy Policy or the processing of your personal data.

E-mail: [E2] contact@lullaai.com . 

2.    WHAT REQUIREMENTS SHOULD YOU MEET IN ORDER TO PROVIDE US WITH YOUR PERSONAL DATA?
2.1. Minimum age. To provide us with your personal details, you must be at least 14 years old. Please note that our Services are aimed at adults, so in order to use them through the App you must be of legal age. LULLAAI will not be responsible for any failure to comply with this requirement.

We do not knowingly solicit data or market services to children under 14. If we become aware of this, we will delete such information within a reasonable period of time.

2.2. Truthfulness. When you provide us with your data to use our services, you guarantee that the data and information provided is real, true, updated and also belongs to you and not to third parties.

In addition, you must notify us of any change in the data provided, responding in any case for the veracity and accuracy of the data provided at all times.

3.    WHAT DATA PROCESSING DO WE DO THROUGH THE WEBSITE AND WHAT ARE ITS MAIN CHARACTERISTICS?
Below, we explain how we process your personal information and provide you, in detail, with all relevant information regarding your privacy:

3.1.       Contact us through our channels (contact form, email, etc.)
What data do we collect?

 
Identification and contact information. We collect the information that you provide to us through the means that we make available to you on this Website. In this sense, we will process your identification data (name and surname) and the e-mail address, as well as any other that you include in the communications that you send us.

Curricular, academic and professional information. If you send us your Curriculum Vitae (CV), we will be able to process the information related to your studies, training, academic experience and that which you have included.
What are the purposes of the processing of your personal data?

 
To answer your requests. The main purpose of the processing of these data will be to answer your requests, solve your doubts and/or provide you with the required information, as well as, if necessary, to follow up on them.

 

Part of the customer service through the chat in the App is carried out by means of automatic software (chatbots), in order to categorise the query and to be able to: (i) answer your query quickly and easily if we have the answer already planned; or (ii) subsequently redirect it to the appropriate operator.

 

Participate in our selection processes. In the case that you send us your CV, we will process your personal information in order to initiate, if necessary, a recruitment process for an eventual hiring and to follow it up.

 

Improve customer service and automate responses. All the information collected from the doubts, consultations, and advice offered to the interested parties, as well as the way in which the requests are resolved, allows us to know how we provide our own customer service, allowing us to improve its quality.

Likewise, all the information collected, once the retention period indicated below has elapsed, is made anonymous and is used for the purposes of analysing the most frequently asked questions through the chat and to be able to automate the most frequent ones, prepare FAQS or be kept for statistical purposes.
What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory?

 
Consent. The data provided for the above purposes will be processed on the basis of your consent, given when you voluntarily contact us through the means made available to you to request information or send us other communications or to send us your CV in order to participate in our selection processes.

Legitimate interest. All the information gathered by the customer service department will serve to improve the quality of the customer service provided, based on our legitimate interest.

 

The information that you must provide is indicated with an asterisk or in a similar way. Without this information it is not possible to provide you with our services.  
How long do we keep your information?

 
All your personal information will be processed during the time your applications are being processed and for 6 months to follow up on your applications. Once this period has expired, LULLAAI will keep, blocked this information during the periods established by the legislation to attend to eventual responsibilities and to demonstrate the fulfilment of our obligations. All this, unless you start a new processing. From this moment, LULLAAI will only process the information in an anonymous way, so that it will not be possible to link the statistical information with the specific users to whom it refers.

In the case of your CV, we will process your personal information during the recruitment process, if applicable, and/or, when there is no open processes, for a maximum of 1 year for possible future recruitment that may fit your professional profile or the interests you have indicated.
To whom do we give your personal information?

 
We do not make any additional transfers of data to carry out this processing other than those indicated, in general, in point 4. To whom do we transfer your personal information?
 

3.2.       Registration, subscription and use of the App
What data do we collect?

 
Data provided by you when registering in the App to configure your account and data that we will ask you to provide in order to comply with the contractual relationship:

 

·       Identification and contact details: When you register in our App, you must fill in a form in which we ask you for basic identification and contact details (name and surname, telephone number, email), in order to register in the App.

 

*Registration using social networks or the appstore account. In the event that you decide to register or log in through a third party social network, we will have access to some of your information included in your public social network account, as well as name and other profile information. At the time of registration, the social network will inform you of the data that will be transmitted to us for registration. In the case of registration by means of the appstore ID, the social network will indicate the conditions for registration.

 

·       Information about your baby: We ask you for some information about your baby that is necessary to create the personalised sleep plan included with the Lullaai subscription. The App also allows you to record information about your baby’s sleep manually, to keep track of your baby’s sleep.

 

Because of the specific purpose of our application, we will process data related to the health of the baby.

 

·       Billing and payment information: We may collect information about your subscriptions and other transactions made through the App.

Payments will be made through the appstore account, so in these cases we will not have information about your bank cards. [E3] 

 

Data collected during the use of the App, to meet the purposes of the App:

 

·       Information about the baby’s sleep: When using the “night mode” available in the App and provided the “Autocalm” function has been activated, information about your baby’s sleep quality and patterns will be collected. This information can also be entered manually when “autocalm” is not activated, as in that case, the information will not be recorded automatically.

·       Environmental sounds (only if “Autocalm” is activated): When you start using the App, we will ask for your consent to use your microphone to pick up environmental sounds so that our technology works. Our system does not record sounds, but our algorithm analyses sounds captured by the microphone, converting them into data. [E4] 

·       App usage information: We may automatically collect technical data and information related to your use of the App, including, the type of mobile device, the unique identification of your mobile device, the IP address of your mobile device, the mobile operating system, if any, the type of Internet browsers you use and information about how you use the App, such as frequency and time of use.
What are the purposes of the processing of your personal data?

 
1.     Manage your account so that we can interact with you.

 

2.     Manage and execute the contractual relationship that unites us: we carry out different steps necessary to execute the contract signed with you, so that, for example, we can provide you with the service, contact you to help you resolve doubts, to verify the information you have provided us with or to make invoicing and payments.

 

3.     Meeting the App’s goals: The main goal of the App is to help you manage and control your baby’s sleep. Through the App, with the information provided, we provide you with content with general recommendations to help you get your baby to sleep, we provide you with a tool (night mode), with which sounds are emitted to help your baby fall asleep, a register to keep track of the baby’s sleep and we provide you with a basic personalised plan with suggestions for your specific case.

 

The information requested before the preparation of the personalised plan will be used to assess the suitability of the plan and, if this cannot be done, to recommend a more personalised service. [E5] 

REMEMBER THAT, AS INDICATED IN THE CONDITIONS OF USE, THE INFORMATION PROVIDED BY LULLAAI THROUGH THE APP WILL ONLY BE FOR TEACHING OR EDUCATIONAL PURPOSES. LULLAAI DOES NOT (AND DOES NOT INTEND TO) PROVIDE A MEDICAL SERVICE OR DIAGNOSIS, SO YOU SHOULD CONSULT YOUR DOCTOR ABOUT ANY DECISION YOU MAY MAKE WITH THE INFORMATION PROVIDED THAT MAY AFFECT YOUR BABY’S HEALTH.

4.     Provide you with an automatic personalised service (“autocalm” system): When you activate the “autocalm” system, it will listen to the sounds of the baby and the environment to adapt the sounds and their volume, to prevent the baby from waking up or to help them fall asleep again.

Every time you use the night mode with the “autocalm” system activated, the information about the baby’s sleep session will be updated automatically, so you can see the evolution of the baby. If you don’t use this system, you will have to enter this information manually.

5.     Profiling to give you more accurate results: When the “autocalm” system is active, our system, in addition to adapting the sounds and volume based on what it “hears” as explained in the previous paragraph, the system will learn, as the App is used, the baby’s sleeping patterns and will adapt its operation to them, managing to foresee when it is necessary to emit certain music, its volume, etc. during the use of “night mode”.

Therefore, the acceptance of the use of a microphone (when the “autocalm” system is activated), implies the acceptance of the creation of a profile of the baby in relation to its sleeping patterns, so that the algorithm, through the application of machine learning techniques, learns and adapts to your baby in a specific way.

6.     Sending of relevant posts and commercial communications: See section 3.4.

7.     Prevention, detection and prosecution of activities that are illegal or contrary to the conditions of service or that endanger information security or the App. LULLAAI may process the data to control and prevent any form of abuse of our services, such as fraudulent activities, denial of service attacks, sending spam, unauthorised access to our users’ accounts, as well as any other practice that is contrary to the General Conditions and Conditions of Use of the App or that endangers the security of the information or the integrity of the App itself.
What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory?

 
Contract execution (purposes 1-2-3-7): The data provided for the above purposes will be processed on the basis of the execution of the contract you sign with us, by virtue of which we provide you with a service to help and manage your baby’s sleep, through content, tools and a personalised basic plan.

Consent (purposes 4-5): The activation of the “autocalm” system, so that the management of the baby’s sleep can be carried out automatically, will be based on the user’s consent, which will be requested the first time you access the night mode or, failing that, when you activate this system.

Processing of health-related data: Data related to the baby’s health will be processed on the basis of your explicit consent, which is requested at the time of registration in our App.

 

In the case of the sending of commercial communications, what is explained in section 3.4 applies.

 

The information that you must provide is indicated with an asterisk or in a similar way. Without this information it is not possible to provide you with our services.  

 
How long do we keep your information?

 
All your personal information will be kept for the duration of our contractual relationship. Once the contractual relationship is over, LULLAAI will keep, blocked, this information during the retention periods established by the legislation in order to attend eventual responsibilities and to demonstrate the fulfilment of our obligations.

In the case of the sending of commercial communications, what is explained in point 3.4 applies

Notwithstanding the above, we reserve the right to use your information in aggregate form after your account is closed for statistical purposes and to improve our Services. The use of such information will not allow you to be personally identified.
To whom do we give your personal information?

 
There are no specific transfers of your personal data to comply with the purpose indicated in this section[E6] . However, we may use the services of service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how our service providers operate, see point 4. > Service providers).
 

3.3.       Special services: Chat service and coaching service
What data do we collect?

 
Data provided by you when registering on the Website platform to set up your account and data derived from the contractual relationship (section 3.2).

 

Data provided by you, when requesting any of the special services we offer through the App:

 

·       Information about your baby: During the provision of the coaching service, additional information will be requested about the baby, their sleep patterns, personal characteristics and other relevant information in order to assist you in managing their sleep.

 

Because of the specific purpose of our application, we will process data related to the health of the baby.

 

This information may be collected through the App itself via chat, via email or through interviews with the coaches (video or phone calls, depending on your preferences).

 

·       Billing and payment information: We may collect information about your transactions and other information needed to process payments.

Payments can be made through the appstore account, so in these cases we will not have information about your bank cards. [E7] 

 

Data collected during the use of the App, to meet the objectives of the App:

 

·       Information about the baby’s sleep: The information collected with the use of the App (section 3.2.) will also be used. [E8] 
What are the purposes of the processing of your personal data?

 
Providing you with personalised advice: The purpose of the personalised services is to provide you with more personalised advice on your specific case, to help you manage your baby’s sleep, taking into account some of your baby’s individual characteristics. Depending on the service selected, the information and advice can be obtained through a chat in the app (chat service) or through calls/videocalls with the sleep coach (coaching service).

REMEMBER THAT, AS INDICATED IN THE CONDITIONS OF USE, THE INFORMATION PROVIDED BY THE COACHES IS FOR EDUCATIONAL OR TEACHING PURPOSES ONLY. LULLAAI DOES NOT (AND DOES NOT INTEND TO) PROVIDE A MEDICAL SERVICE OR DIAGNOSIS, SO YOU SHOULD CONSULT YOUR DOCTOR ABOUT ANY DECISION YOU MIGHT MAKE WITH THE INFORMATION PROVIDED.
What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory?

 
Contract execution: The data provided for the above purposes will be processed on the basis of the execution of the contract you have signed with us, by virtue of which we provide you with a service to help and manage your baby’s sleep.

Processing of health-related data: Data related to the baby’s health will be processed on the basis of your explicit consent, which is requested at the time of registration in our App.   

 

The information that you must provide is indicated with an asterisk or in a similar way. Without this information it is not possible to provide you with our services.  
How long do we keep your information?

 
All your personal information will be kept for the duration of our contractual relationship. Once the contractual relationship is over, LULLAAI will keep, blocked, this information during the periods foreseen by the legislation in order to attend eventual responsibilities and to demonstrate the fulfilment of our obligations.

Notwithstanding the above, we reserve the right to use your information in aggregate form after your account is closed for statistical purposes and to improve our Services. The use of such information will not allow you to be personally identified.
To whom do we give your personal information?

 
There are no specific transfers of your personal data to comply with the purpose indicated[E9]  in this section. However, we may use the services of service providers to comply with the indicated purposes, who will be subject to the duty of confidentiality and to the instructions of LULLAAI.

For example, for the coaching service you will need to book an appointment through the Calendar application, where you can select the date and time that suits you best.

(For more information on how our service providers operate, see point 4. To whom do we give your personal information? > Service Providers).
 

3.4.       Marketing and sending commercial communications [E10] 
What data do we collect?

 
Data provided by you when you register in our commercial communications or when you register in the App:

·       Identification and contact data: To send commercial communication by electronic means, we use the contact data you include in the corresponding form or those contact data (e-mail or mobile phone) that we have by virtue of our contractual relationship (registration in the App).
What are the purposes of the processing of your personal data?

 
1.     Sending of relevant posts and own commercial communications: If you have a contractual relationship with us or have expressly requested it, we can send you, through electronic means, commercial communications about our products and services.

 

2.     Sending of third parties’ commercial information: If youauthorise us to do so, we may send you commercial information about products or services from third parties with whom we have collaboration agreements for this purpose.
What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory?

 
Commercial communications are sent:

ü  On the basis of our previous contractual relationship; or

ü  based on your consent, requested at the time of registration in the App or by checking a corresponding box in other forms.

You may unsubscribe from these commercial communications at any time through the mechanism indicated in each email or by writing your wish to unsubscribe to the email contact@lullaai.com.
How long do we keep your information?

 
All your personal information will be kept for the duration of our contractual relationship. Once the contractual relationship is over, LULLAAI will keep, blocked, this information during the periods foreseen by the legislation in order to attend eventual responsibilities and to demonstrate the fulfilment of our obligations.

In the event that the sending of commercial communications is based on your consent, we will keep the information for as long as you are registered on our distribution list for this type of information and, once you have unsubscribed, it will be kept blocked for the legal retention periods established to deal with any possible responsibilities.
To whom do we give your personal information?

 
There are no specific transfers of your personal data to comply with the purpose indicated[E11]  in this section. However, we may use the services of mail marketing service providers or other advertising and marketing service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how our service providers operate, see point 4. > Service Providers).
 

3.5.       Cookies on our Website and App
What data do we collect?

 
We can automatically collect:

Web Site or App usage information: When you access the Web Site or our App, even if you have not registered, information is collected through cookies or other tracking tools. These tools are small files that are downloaded to your device and collect data about your use of the Web site or App. Through these tools, we may collect:

·       Device information: We collect information about the mobile device from which you access the Website or App. The information we collect is the device model, operating system and version, unique device identifier and network.

·       Information about your location: We can also obtain the IP address, time zone and what is the mobile service provider, if any, which allows us to obtain a general location.

·       User navigation information: We collect information about your use of the Website or the App, including frequency of use, sections visited, use of specific functions, etc[E12] 
What are the purposes of the processing of your personal data?

 
Perform statistical analysis and improvement of the Website and the App: All the information collected through cookies and other tracking tools help us to analyse, maintain and improve the Website and the App, since from the analysis of the navigation and use made by the users, we can detect errors, aspects to be improved in the design or the need to add new functions and services.

 

Advertising on the Website and social networks[E13]  : Advertising may appear on the Website or App[E14]  in the form of pop-ups or advertising banners integrated within the content itself. These banners would link to third party websites for advertising and/or information purposes and would in no case be the responsibility of LULLAAI. The advertising that appears in these banners may include personalised advertising, derived from information obtained from Cookies or other tracking devices that allow the collection of information and the display of advertisements related to your recent searches and others that are relevant to you. Similarly, we use third-party advertising services to serve ads for our Services on other websites.

Even if you choose not to receive customised ads depending on your browser settings, generic ads or ads may still appear depending on other factors, such as your general location.

In addition, from the social network tracking devices that are set up on the Website (see Cookie Policy), we can create an audience for the matching process on the relevant social networks. The data that is sent is encrypted in our systems before it is uploaded and provided to the social network and then used to display LULLAAI advertising on your social networks. To find out more, please visit:

https://es-es.facebook.com/legal/terms/customaudience.

 

For more information on which cookies we use, you can visit our Cookie[E15]  Policy.

 

Prevention, detection and prosecution of activities that are illegal or contrary to the conditions of service or that endanger the security of the information or the Website. LULLAAI may process the data in order to control and prevent any form of abuse of our services, such as fraudulent activities, denial of service attacks, sending of spam, unauthorised access, as well as any other practice that is contrary to the General Conditions and Conditions of Use of the Website[E16]  or that endangers the security of the information or the integrity of the Website itself.
What is the basis of legitimacy that allows us to process your data? Is the provision of this data mandatory?

 
The information we collect through cookies and other tracking devices is based on your consent, which we request when you access the Website[E17]  or App. All this information may be used, based on our legitimate interest, to analyze and evaluate the use made of our Web Site and to implement the necessary improvements to it.
How long do we keep your information?

 
The retention periods for information collected through cookies depend on the specific cookie. All retention periods are specified, for each cookie, in our Cookie Policy[E18] .
To whom do we give your personal information?

 
The transfer of personal data through cookies from third parties (cookies collected and managed by a third party) for this purpose is specified in the Cooki[E19] es Policy. In addition, we may use the services of service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how our service providers operate, see point 4. > Service providers).

If at any point we decide to show you advertising through the Website or App, we may share certain information with third-party advertisers and networks and use that information to provide you with targeted, personalized advertising and statistical analysis. In addition, advertisers may share with us data they collect about you to display our advertising on other sites. [E20] 

For more information, please visit our Cookie Policy.
 

4.    LULLAAI profiles in social networks.
LULLAAI has a profile on the main social networks, such as Facebook, Twitter, Instagram, Linkedin or YouTube.

When you become a follower of one of our pages in the social networks, the processment of the data will be governed by the conditions of use, privacy policies and access regulations that belong to the corresponding social network and previously accepted by the user.

LULLAAI, in this sense, will process your data for the purpose of correctly managing its presence on the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of social networks allow.

Please note that we have no influence over the information that the social network collects or how it is processed, so we recommend that you keep yourself informed of the purpose and extent of information collection that takes place through such social networks.

4.1.        Use of plug-ins or social add-ons

When you use our Website or App, you can share information on social networks, such as Facebook or LinkedIn, through an implemented social plug-in (such as a “Share” button). If you choose to share information via a social plug-in, the following data will be transferred to the relevant social network:

                                 I.                 Date and time of visit;

                              II.                 The Internet address or URL for the address you are temporarily visiting;

                            III.                 The IP address;

                             IV.                 The browser you are using;

                               V.                 The operating system you are using;

                             VI.                 Where applicable, your username and password and if you are a registered user of the social network, first and last name; and

                           VII.                 The information for which you have used the specific plug-in

With respect to such information, we refer to the terms and conditions of the relevant social network. We encourage you to keep informed of the purpose and scope of the information collection that takes place through the social plug-ins.  If you wish, you can block social plug-ins in your browser settings. Please note that we have no influence over the information that the social network collects through the use of plug-ins. [E21] 

5.    TO WHOM DO WE GIVE YOUR PERSONAL INFORMATION? [E22] 
In general, LULLAAI will not transfer your data to third parties. However, in addition to the assignments that we specifically indicate in the section in which we explain the characteristics of the different operations (section 3), we inform you of the communications that we can make, in general, and that affect all the previous processing and its legitimating basis.

i.               Essential service providers to execute the service we offer you, (e.g. computer hosting companies or commercial communication delivery platforms). Notwithstanding the above, these entities have signed the corresponding confidentiality agreements and will only process your data according to our instructions, not being able to use them for their own purposes or apart from the service they provide to us.

International transfers. Some of our service providers are located in the United States or other countries outside the European Economic Area. The services of these providers imply the existence of an international transfer of your personal data, which could imply a lower degree of protection than that provided for by European regulations. However, all such suppliers have signed with us the relevant standard contractual clauses approved by the European Commission. Therefore, the use of these suppliers does not result in a lower level of protection of your personal data than the use of suppliers located in the European Union.

ii.              Public bodies. We may disclose to the relevant public authorities data and other information in our possession or accessible through our systems when there is a legal obligation to do so, as well as when required to do so, for example, when the purpose is to prevent or prosecute abuse of the services or fraudulent activities through our Website or web page. In these cases, the personal data you provide us with would be kept and made available to the administrative or judicial authorities.

iii.             In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of your assets or any other corporate transaction involving a third party, we may share, disclose or transfer user data to the successor entity (including in the pre-transaction phase).

iv.            To third parties following aggregation or anonymisation: we may disclose or use aggregated or anonymised data (i.e. data that cannot be linked to an identified or identifiable individual) for any purpose.

v.             To third parties with the user’s consent or other legitimate basis: In the event that we wish to share data with third parties outside the scope of this Privacy Policy, their consent will be requested in any case or they will be informed about it and its legitimate basis.

We also inform you that this Privacy Policy only refers to the collection, processing and use of information (relating to personal data) by us through the interaction you have with our Website or App. Access to third party websites or platforms that you may access through links from the Website or App have their own privacy policies over which we have no control. Therefore, before you provide them with any personal information, we recommend that you inform yourself about their Privacy Policies.

6.    WHAT ARE THE RIGHTS YOU CAN EXERCISE AS AN INTERESTED PARTY?
You can exercise the rights guaranteed by law in relation to the processing of your personal data by contacting our Data Protection Officer by e-mail at contact@lullaai.com.  [E23] 

Any request for rights we receive will be resolved as soon as possible and in any case within 1 month of receipt. In some cases, it will be necessary to request a copy of your identity card or other identification document if it is necessary to verify your identity.

Your rights as an interested party are as follows:

i.               Right to withdraw consent given

You may revoke your consent in relation to all prosecutions based on it at any time. However, withdrawal of consent shall not affect the lawfulness of processing based on consent prior to withdrawal.

ii.             Right of access

You have the right to know what data is being processed, if any, and, if so, to obtain a copy of it, as well as to obtain information concerning

Ø  the origin and recipients of the data;

Ø  the purposes for which they are intended;

Ø  whether there is an automated decision-making process in place, including profiling

Ø  the data retention period; and

Ø  the rights provided for by the regulations.

 

iii.            Right of rectification

You have the right to obtain the rectification of your personal data or to complete them when they are incomplete.

iv.            Right of withdrawal

You have the right to request the deletion of your personal data if they are no longer necessary for the purpose for which they were collected or, where appropriate, if we are no longer authorised to process them.

v.             Right to data portability

You have the right to request the portability of your data in the case of processing of your data that is based on your consent or on the execution of a contract, provided that the processing has been carried out by automated means. If you exercise this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you may also request, where possible, that your data be transmitted directly to another company.

vi.            Right to limit the processing of your personal data

You have the right to limit the processing of your data in the following cases

a)    When you have requested the correction of your personal data during the period in which we verify the accuracy of the same.

b)    When you consider that we are not authorized to process your data. In that case, you can ask us to limit their use instead of requesting their deletion.

c)     When you consider that it is no longer necessary for us to process your data and you want us to keep them for the purposes of the exercise or the defence of claims.

d)    In cases where there is processing based on our legitimate interest and you have exercised your right to object to this, you may ask us to limit the use of your data during the verification of the prevalence of such interests over your own.

vii.          Right of opposition

You have the right to object at any time to the processing of your personal data on the basis of our legitimate interest, including profiling.

Unsubscribing from commercial communications: Remember that at any time you can unsubscribe from receiving this type of communication by sending an email to contact@lullaai.com. You can also exclude yourself from this service by following the instructions indicated at the bottom of the body of each of the electronic communications that we send you.

viii.        Right to lodge a complaint with the Supervisory Authority

Remember that, at any time, and in the event that you consider that we have infringed your right to the protection of your data, you may address the corresponding Control Authority, in the case of Spain, the Spanish Data Protection Agency (www.agpd.es).

7.    HOW DO WE GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?
The security of your personal data is a priority for us. For this reason, LULLAAI has implemented all the necessary security measures to guarantee an efficient use and processing of the personal data provided by the user, safeguarding the privacy, confidentiality and integrity of the same and making use of the necessary technical means to avoid the alteration, loss, unauthorised access or processing of your data, according to the state of technology at any given time.

Consequently, we comply with the recommended security standards to protect them. However, it is impossible to fully guarantee your security because of the very nature of the internet and because there may be malicious actions by third parties outside our control.

We are committed to acting quickly and diligently if data security is compromised or compromised, and to informing you about it if it is relevant.

8.    WHAT REGULATIONS AFFECT THIS PRIVACY POLICY?
If you would like more information about the regulations that assist, protect and establish your rights, we make available the laws that have inspired this policy and are relevant to you:

–        General Data Protection Regulation EU 216/679

https://www.boe.es/buscar/doc.php?id=DOUE-L-2016-80807

–        Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.

https://www.boe.es/eli/es/lo/2018/12/05/3

–        Law 34/2002, of 11 July, on information society services and electronic commerce

http://www.boe.es/buscar/act.php?id=BOE-A-2002-13758

9.    CHANGES TO THIS POLICY
We can modify the content of the privacy policy at any time, especially when there are changes in legislation, case law or interpretation by the Spanish Data Protection Agency.

LULLAAI will try, as far as possible, to notify you of any changes to this policy, although we recommend that you periodically review this Privacy Policy to be informed of how your personal data is processed and protected, as well as your rights.

 

This Privacy Policy has been amended on 29 September 2020.