Privacy Policy

Below is our Privacy Policy describing how and why we process out users’ personal data, as well as the laws that govern such processing, and outlining our commitment to the privacy and security of our users’ information, based on the principles of confidentiality, integrity, transparency and availability.

1. Controller

This Privacy Policy ("Privacy Policy") describes how P.R.S. MARKETING SERVICES, S.L. (hereinafter, "Minube"), a Spanish company registered at Calle Loeches, nave 65.9, 28925, Alcorcón, Madrid and with Tax Identification Number B83737064, collects, processes and uses the personal information of the users of its platform.

This Privacy Policy applies to the information we collect from users through our website and app, electronic communications, contact forms and any other services that we implement to improve the experience of our users.

The Privacy Policy will be updated periodically in order to clarify or reflect new practices in the processing of our users’ data or new legal modifications that should be applied. Users will be notified of all changes to the Privacy Policy by email (sent to the email account used upon registration), and through public notices on our platform.

2. Situations in which we process users information

2.1 When we collect personal data: If you interact with us through our website, we can collect different data through forms that appear on the website. If you register with us through a social network, using what is called "social login" or "plug-ins", we will process your username and password, email, and that information that you have made public via your social profile or that is given through your browser, such as your social profile picture (you can always change it if you prefer to use another one), so you can correctly register on our website.

2.2 How your data is collected:

We process your data whenever:

• you visit our website;
• you interact, connect with or link to our website through social networking sites, blogs or other websites;
• you use any of our electronic communication services, you send us an email or use our messaging service, if applicable; The personal data that you provide us when using any of our services will be incorporated into our database, which is duly registered in the General Registry of the Spanish Agency for Data Protection.

In the following, we will give you more details about the situations where we collect your data:

• When you register as a user, specifically when you complete the user registration form. We can collect your name and surname, photo and email.

We can also collect information about your use of our services, such as technical information as well as when, where and how you use our services. In this regard, we can collect the following information:

• a. Technical information about your device and internet connection Through logs and other tools we record information about your internet connection and device, including the operating system and other unique identifiers. This type of information is generally used in an aggregate way to analyze how our website and services are used, and to make improvements to our services.
• b. Information about the use of our services We register the activity performed by your account, as well as the visits you make to the website for the purposes of, among others, preventing fraud, improving our services and providing personalized services, recommendations and publicity.
• c. Location information By using our services, you have the possibility of activating geolocation services that allow us to better personalize the services we offer you.

2.3 What we use the collected data for: The personal data you provide us when registering or using our services will be used for the management, administration, provision, expansion and improvement of our services, specifically those you have used or to which you have subscribed, as well as to keep you informed about improvements to and new features of the services we offer.

In this sense, we use your data with the following objectives:

• Operate, maintain and improve our website.
• Answer your questions and respond to your requests;
• Send you reminders, technical notices, updates, security alerts, support and administrative messages;
• Manage our daily business tasks, such as the administration of the website, the use of analytics, the fulfillment of our obligations determined by the Conditions of Use and compliance with legislation;
• Fulfill our legal obligations, resolve disputes and avoid inappropriate use.
• Improve user experience by analyzing user information to better understand the users and their interests and offer more relevant and attractive services. Likewise, data is processed to analyze user behavior in order to identify possible improvements related to the different services provided by Minube.

In the specific case that you contact us by e-mail or through any other customer service channel, your data will be used to answer the queries transmitted through this medium.

In the following, we will detail the purposes of collecting user data:

• 1. To register you as a user of our network By using our user registration forms and accepting our privacy policy, you give us consent to process your personal data and all other information you provide us with so that you can search and share your travel experiences, and for all other purposes described in this privacy policy. Remember that in some cases part of your information may be public, that is, it may be visible to other users of the website and may be indexed by online search engines. If you do not want this information to be public, you will have to edit your visible information through the menu available on your profile page.
• 2. To contact the user By using any of the available forms to contact other users, and after accepting the privacy policy, you give us consent to share your personal data and all other information you provide through this form with the user to establish the contact, as well as with the purpose of being able to inform you about characteristics, conditions and any other information that is of interest relative to your travels and experiences.
• 3. To serve advertising We will also process your personal data to serve advertising: • You are conscious that your data may be used by Minube for advertising communications relating to the services of the website, including newsletters. In some cases, processing data for advertising may involve the communication of your data to third parties in order to perform cross-checks to determine if you are in fact a user and to avoid duplicate shipments. You authorize your data to be processed for this purpose, unless you deny authorization as described below: You deny the use of your data for advertising purposes via the settings on your profile page.
• 4. To improve our services We can also use the data you provide us to analyze your use of our services and obtain information about behaviors and interactions.
• 5. Market analysis We may also use your data to analyze and understand market trends so that we can improve, develop and customize our services. These analyses can be carried out directly or through third parties that analyze said data at our request (said processing will be subject to the corresponding data processing agreements that guarantee the confidentiality and integrity of the same). This type of analysis allows us to detect the needs of our users and adapt our services in a more personalized way.
• 6. To create user profiles We may also use your data to evaluate certain personal aspects of our users and customers, in particular to analyze or predict your personal preferences, interests, reliability, behavior, location or movements.
• 7. To prevent fraud and abuse We will also use your data to control and avoid any form of abuse of our services, such as fraudulent activities, denial of service attacks, spam, unauthorized access to our users' accounts and any other practice that is contrary to the Conditions of Use of our website.
• 8. Third-party data In the case you include personal data of a third parties, you must inform him/her of the ends contained herein and have their consent prior to their inclusion.
• 9. Minimum age restriction If you are a minor you cannot use the services offered by our website. Be informed that, in accordance with the regulations in force, specifically articles 314 and 323 of the Civil Code that establish that minors, except those who have obtained emancipation, cannot enter into contracts unless there is authorization from the parents or guardians.

3. How to exercise your rights:

As a user you can: (i) solicit access to any personal data we have about you and request that we update, rectify or remove it, (ii) require us to refrain from using any personal information we have about you, and / or ( iii) deny the processing of your data. The emails we send contain links which let you opt-out of advertising, and if you wish to exercise any of your rights you can contact us through these links embedded in all Minube emails or through post to the following address: Calle Loeches, nave 65.9, 28925, Alcorcón, Madrid. Remember to provide as much information as possible about your request, such as your name and surname, the email address you use to access your account and the purpose of your request.

3.1. Reporting a violation of your rights: In any case of a violation of your right to personal data protection, you can report to the corresponding National Control Authority, the Spanish Agency for Data Protection, www.agpd.es, to initiate the appropriate procedures in defense of your rights.

4. Deactivation of your user account :

Any user can deactivate his/her account on the website at any time. You can do this by going to your profile and entering with your username and password. In case of deactivation (closing your account), you will lose the information and data possibly stored in your account, as well as the right to use any services previously contracted as a user of the website. In the case that your request deactivation, we can keep all of your personal data for the period of time necessary to guarantee our legal obligations and to resolve possible disputes. All of your personal data will be processed and conserved to the extent strictly necessary to comply with the law or with the purposes that we have described. When your data is no longer relevant to the purposes for which it was collected, it will be deleted or anonymized, including any registration or other supporting information.

5. With whom can we share your data?

As stated in point 3.2, we will send your contact information to the user who has published an article in which you are interested, and will additionally share some of your data with:

• 1. Legal authorities Minube guarantees the confidentiality of personal data. However, we may disclose to the appropriate public authorities the Data and any other information that is in our possession or that is accessible through our systems and is required in accordance with the legal provisions applicable to the case. This will be done in order to prevent fraud or the abuse of the services provided through our website. Therefore, and in accordance with section four of this Privacy Policy, personal data that you provide us may be kept and made available to administrative or judicial authorities.
• 2. Service providers Minube may have contracted different services with providers that access personal data. All the providers have signed personal data processing agreements limiting their treatment to the purposes of the service and always under the security measures established by current regulations.

6. Veracity of data and responsible use:

Having an account or being a user of Minube means that you have to guarantee, both to Minube and to third parties, the quality of the information provided, that is, that the data and information provided is real, accurate, up-to-date and pertains to you and not to a third party. Therefore, you guarantee that your data is true. Minube reserves the right to verify this information at any time by requiring an official document or equivalent measure and, if necessary, to temporarily deactivate and / or cancel your account. Minube is concerned with ensuring the security and confidentiality of your personal information and data. For this reason, we have adopted numerous security measures and technical means to prevent their loss, misuse or access without your authorization. Notwithstanding the above, it is also up to you to protect your personal information and that is why we recommend that you be careful with the information you share and with whom you share it. Minube cannot protect the information you choose to share with other users and, therefore, we are not responsible for the consequences of your own actions. However, we are committed to act quickly and responsibly in the event that the security of your data may be in danger, and to inform you if it is relevant.

7. Plug-ins and social services:

When you use our services, you can share information about the Services on social networks, such as Facebook and Google+, through a social plug-in. If you choose to share information through a social plug-in, your browser will transfer the following data to the social network:

• a. Date and time of visit;
• b. The URL of the address you are visiting temporarily;
• c. Your IP address;
• d. The browser you are using;
• e. The operating system you are using;
• f. Your username and password and, where appropriate, if you are a registered user of the social network, first and last name; and
• g. The information for which you have used this 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 about the purpose and scope of the information collected through social plug-ins. If you wish you can block the social plug-in through your browser settings. Keep in mind that we do not have control over the information that the social network collects through the use of plug-ins.

8. Special Privacy Policies and Third party privacy policies:

8.1. Special Privacy Policies For some services of our website, you will have a service-specific privacy policy in addition to this general privacy policy. In that case, the terms of both privacy policies will be applicable. In the event that some of the clauses are contradictory, be advised that the clause of the service-specific privacy policy will apply.

8.2. Third-Party Privacy Policies This Privacy Policy only refers to the collection, processing and use of information (relating to personal data) on our part through the interaction you make with our website. Other third-party websites that you access through links from Minube have their own privacy policies. We encourage you to read the privacy policies offered by these third parties before providing any personal information.

9. Secutiry measures:

Minube has implemented the necessary security measures to guarantee the use and treatment of personal data provided by the user, safeguarding the privacy, confidentiality and integrity thereof, and complying with the regulatory requirements set forth in REGULATIONS (EU) 2016/679 OF THE EUROPEAN COUNCIL AND PARLIAMENT of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of these data and repealing Directive 95/46 / EC (General Regulation on the protection of personal data) data), making use of the necessary technical means to avoid alteration, loss, unauthorized access or treatment of your data, depending on the state of the technology at any time, as well as the scope of control of Minube.

Minube, may modify the content of its privacy policy at any time according to legislative, jurisprudential or interpretation amendments of the Spanish Agency for Data Protection that may occur.

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