Terms of Service

FLEBI PRIVACY AND PERSONAL DATA PROTECTION POLICY

For the team at FLEBI SOLUCIONES S.L., owner of this website, the protection of personal information, its security and confidentiality is of utmost importance. Therefore, we recommend that you carefully read the following Privacy Notice, since the information that you provide as a user through this website https://www.flebi.com, is protected under the terms of this Privacy Policy.

SUMMARY OF INFORMATION CHART

BASIC INFORMATION ON DATA PROTECTION
Responsible	FLEBI SOLUCIONES S.L./ B-91951418
Purposes	Show the products offered Execution of the contract/purchase Manage your registration as a user of our services Management and response to online queries Sending promotions and advertising about the services offered Usability and quality analysis of the website
Legitimation	Consent of the interested party and execution of contract.
Recipients	Data will not be transferred to third parties, unless legally required. Analytical results may be transferred upon request of installed tools. For more information, consult the Cookies Policy.
Rights	Access, rectify and delete data, limit and oppose processing, data portability and withdraw consent.
Additional information	You can consult additional and detailed information on Data Protection by continuing to read this notice.

WHAT DOES THE PROCESSING OF PERSONAL DATA MEAN?

The operations, procedures and technical processes that are carried out in an automated or non-automated manner and that enable the collection, storage,

Modification, transfer and other actions on personal data are considered to be the processing of personal data.

WHAT DOES THE USE OF THE WEBSITE MEAN?

Before sending any request for information through any form available on the FLEBI website, or by email, the user must read and accept this Privacy Policy, thereby giving his or her unequivocal, free, specific and informed consent to the processing of his or her personal data for the purposes indicated. Our internal mechanisms prevent personal data from being sent without having clicked on express consent.

The aforementioned express consent implies the authorization of the processing of your data by FLEBI under the terms established in this Privacy Policy, as well as by the joint controllers and data processors with whom FLEBI maintains an obligatory contractual relationship and compliance control.

WHO IS THE DATA CONTROLLER?

• • Data controller: FLEBI SOLUCIONES S.L.
• • C.I.F.: B91951418
• • Address: Polígono San Nicolás calle 8 nave 99, 41500 – Alcalá de Guadaira (Sevilla)
• • Email: legal@flebi.com
• • Phone number: (+34)955300233

FLEBI guarantees the confidentiality and privacy of the personal data collected, having adopted security measures to prevent alteration, loss, treatment or unauthorized access and to guarantee the integrity and security of personal data, in accordance with the provisions of Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, which develops Organic Law 3/2018 of December 5 on the Protection of Personal Data and Guarantees of Digital Rights, providing for this purpose the necessary technical means to prevent any alteration, loss, unauthorized access or misuse of the data processed, in accordance with the nature of the data, the state of the technology, and the risks to which they are exposed.

FOR WHAT PURPOSE WILL WE USE THE COLLECTED DATA?

FLEBI informs you that the personal data you provide through this website, including the IP address, will be processed for the following purposes:

1. Provide the requested service or product appropriately and with all guarantees.

2. Send informative, advertising and commercial communications.

3. Respond to queries about our service, our policies or any other questions, made through any of the communication mechanisms offered on the FLEBI website.

4. Respond and send information to the interested party about our privacy policy or request to exercise rights in relation to Data Protection.

5. Manage our social networks with respect to the data of people who become followers. In this regard, the processing of data is governed by the provisions of this Privacy Policy and by the terms and conditions, privacy policies and access regulations specific to each social network.

6. Conduct periodic web analysis studies for statistical purposes based on the data provided.

7. Analyze user behavior during web browsing.

8. Comply with relevant legal obligations, as well as prevent fraud.

We will not use your data for any other purpose not stated in this privacy policy, nor will we send you additional information not requested with your express consent.

WHAT IS THE LEGITIMATION OF THE TREATMENT?

The legitimacy of the different processing activities carried out by FLEBI are:

• For the purpose of providing the contracted service or executing the transaction carried out, the processing is based on the execution of a contract between the parties.

• For customer service purposes, processing is based on the consent of the interested party and the execution of a contract between the parties.

• For marketing and commercial management purposes, processing is based on the consent of the interested party.

• For the purposes related to the analysis of user behaviour on the website, the processing is based on the legitimate interest of FLEBI, which is based on the search for improvement of the platform, its functionality, its adaptation to users and the provision of a more individualised service for the interested parties themselves.

• For purposes related to compliance with legal obligations, the processing is based on the legal basis enabled for this purpose in the LOPDGDD.

DO WE SHARE THE DATA?

FLEBI undertakes not to transfer data to third parties without obtaining the express consent of users. However, it may transfer metrics and analytics requested by computer tools installed on the website owned by others than FLEBI; some of these services may be owned by third parties residing outside the European Union (Google, Trusted Shops Trustbadge, etc.). For more information, please consult our Cookies Policy, and if in doubt, you can disable cookies.

In this regard, all information handled by FLEBI is stored on the servers of the telecommunications service provider WEBEMPRESA EUROPA, S.L. These servers are located in Europe. If, due to circumstances beyond FLEBI’s control, said data had to be transferred to other servers located in third countries that do not guarantee the privacy required by European regulations, FLEBI will act immediately to ensure that the confidentiality, integrity and availability of the information is respected as regulated by Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD); Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of personal data of natural persons with regard to the processing of personal data and the free circulation of these data (RPDD); and Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSICE or LSSI).

WHAT IS OUR POLICY WITH DATA PROCESSORS?

At FLEBI we only share personal information with third parties for the purpose of providing services or carrying out commercial operations under the terms described in this Privacy Policy or when we consider that the law allows or requires it. Most of the time, what we share with third parties is non-personal, anonymous or statistical data. When we share personal information, we do so in accordance with the privacy and data security requirements previously reported in each case and under the signature of private data processor contracts, in which they ensure that our suppliers comply with the appropriate security measures for complete data protection and legal compliance.

WHAT DO WE DO WITH DATA ON SOCIAL MEDIA?

FLEBI has channels on the social networks Instagram, Twitter, Facebook and YouTube, with the main purpose of publishing and disseminating information about the services offered through the FLEBI website, providing technical support information to customers about the products purchased, interacting with users, and serving as a channel for social interaction and support.

If you access this website using an application that connects a social network with this website, you will be authorizing the social network to share some data with FLEBI.

It is important for you to know that if your social media accounts are geolocated, your location information when shared on social media will be visible to third parties with whom you share or who share your information.

You can find out more about the use of your data on these social networks by consulting the privacy policy of each of them.

WHAT RIGHTS DOES THE USER HAVE?

HOW ARE RIGHTS EXERCISED?

How can you exercise your rights? At any time, the user may withdraw their consent and exercise their rights of access, rectification, deletion, limitation, opposition and portability provided for in the Data Protection Regulation 679/2016 and Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights, by sending an email to legal@flebi.com or to the postal address Polígono San Nicolás calle 8 nave 99, 41500 – Alcalá de Guadaira (Seville).

What do we need to verify your identity? The user must accompany his/her communication with a copy of his/her national identity document, passport or other valid identification document.

Is there a template for exercising rights? You can request our template by emailing legal@flebi.com or by going to the address Polígono San Nicolás calle 8 nave 99, 41500 – Alcalá de Guadaira (Seville).

You can also use the models and forms that the portal of the Spanish Data Protection Agency makes available to you for the exercise of these rights, which can be found at the following address:

http://www.agpd.es/portalwebAGPD/CanalDelCiudadano/derechos/principales_derchos/index-ides-idphp.php

WHAT DO THESE RIGHTS CONSIST OF?

• Right to information: the interested party must be informed in advance in an express, precise and unequivocal manner of, among other things, the existence of a file, the possibility of exercising their rights and the person responsible for the processing.
• Right of access: allows citizens to know and obtain free information about their personal data that is being processed.
• Right to rectification: This right is characterized by allowing errors to be corrected, data that is found to be inaccurate or incomplete to be modified, and the certainty of the information being processed to be guaranteed.
• Right to cancellation: allows the deletion of data that is found to be inadequate or excessive without prejudice to the blocking obligation contained in the LOPD.
• Right to object: The right to object is the right of the affected party to prevent the processing of their personal data or to stop such processing.
• Right to restriction: the user has the right to decide which personal data he or she does not want to be processed in the future, and may exercise this right when he or she has previously challenged the accuracy of the data; when the processing is unlawful and instead of deleting the data, he or she decides to limit it for future processing. In the event of limitation of processing, the restriction may be lifted if there is consent from the interested party; there is a possibility that the processing affects the protection of the rights of another natural or legal person; there is a judicial procedure that justifies it; or there is an important reason of public interest based on current legislation.
• Right to portability: you have the right to receive the personal data provided or to have FLEBI transmit them to another controller, in a structured format for common use and machine reading, provided that the processing is carried out by automated means and the processing is based on the consent that the User once gave for one or more specific purposes, or for the execution of a contract to which he or she was a party. The right to portability will not apply when the transmission is technically impossible; or when it may negatively affect the rights and freedoms of third parties; or when the processing has a mission of public interest based on current legislation.
• Right to lodge a complaint with the Supervisory Authority: You have the right to lodge a complaint with the Spanish Data Protection Agency (supervisory authority in Spain) through the following link: https://www.aepd.es/

OTHER RIGHTS

• Right to be forgotten: Elimination of names from search engine results lists.

• Advertising rights: Right to be excluded from telephone directories, Right not to receive unwanted advertising, Rights of subscribers and users of telecommunications services,

WHAT SECURITY MEASURES DO WE HAVE APPLIED TO THE PROCESSING OF PERSONAL DATA?

At FLEBI, for the protection of the personal data of its users, we have security protocols and the application of technical and organizational measures appropriate to the state of the art, taking into account the scope, context and purposes of the treatment, as well as the risks of variable probability and severity for the rights and freedoms of the interested parties, seeking to be able to ensure the confidentiality, integrity, availability and resilience of the treatment systems and services.

Furthermore, we take care to ensure that our data processors are correctly selected in compliance with Data Protection regulations.

In particular, FLEBI has the following measures:

1.- Privacy and security risk assessment strategy, as well as a disaster recovery plan designed to safeguard the continuity of our services and to protect our staff and our data.

2.- Implementation of Technical and Organizational Security Measures: We apply technical and organizational measures to the functions described in this privacy policy.

3.- Backup protocol: FLEBI has designed a backup system that guarantees the availability of the information stored on its servers.

4.- Periodic training and awareness-raising of our staff and collaborators to avoid errors in data management.

5. Identification and Authentication System: to provide access only to the necessary data and to the specific profile that uses it.

NOTIFICATION OF PERSONAL DATA SECURITY BREACHES

In the event of a breach of the security of personal data, provided that it is not unlikely that such a breach of security constitutes a risk to the rights and freedoms of natural persons, FLEBI will notify the Spanish Data Protection Agency.

of Data within 72 hours from the date of the incident, describing the nature of the violation, the possible consequences that could arise and the measures adopted or proposed to remedy the security breach; and if possible, the categories and approximate number of interested parties and data affected will be made known.

Furthermore, FLEBI will notify interested parties as soon as possible when it is likely that the violation of the security of personal data entails a high risk for the rights and freedoms of natural persons, describing the possible consequences that could arise and the measures adopted or proposed to remedy the security breach.

HOW LONG DO WE STORE THE DATA?

The personal data provided to FLEBI will be deleted once the relevant period for filing claims has elapsed. In cases where the processing is based on the consent of the interested party, the data will be kept until the interested party requests its cancellation or deletion, or withdraws their own consent, or is no longer necessary to meet the purpose for which it was collected.

COOKIE POLICY

In the link “Cookie Policy” we inform you that this website may use cookies (small information files that the server sends to the computer of the user who accesses this website) to carry out certain functions that are considered essential for the correct operation and display of the site, to share on social networks and, in some cases, to perform statistical analysis of evaluation and proposals for improvement.

In order to obtain these analyses, this website may automatically store certain information in the server logs through the use of cookies that collect usage and navigation data related to your use of this website as a user.

The IP is considered personal data. FLEBI does not associate IP addresses or other data generated by the use of cookies or the results of metrics with identifiable information of people, nor to collect personal information, although it may occasionally be used to direct advertising or segment users to whom to direct it.

As a user, it is important that you know that we use Internet tools and platforms that install cookies that do not depend on us, so it is possible that the owners of said tools use said data for other purposes.

For this reason, it is advisable that you read the “Cookies policy” to find out which ones are your own, which are from third parties, which are permanent, temporary or session cookies; and you can decide to uninstall those you consider appropriate, since it will not greatly affect the result, comfort or browsing experience.

PRIVACY OF MINORS

Pursuant to Article 7 of Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, minors under 14 years of age must not provide their personal data to FLEBI without the prior consent of their parents or guardians.

In the event that FLEBI detects users who may be under 16 years of age, it reserves the right to request a copy of their ID or equivalent document, or, where applicable, the authorization of their parents or guardians, causing their deregistration if they do not prove compliance with this requirement or lack of response.

USER RESPONSIBILITY

As a user, you accept and guarantee that the personal data you provide is true, and that you are solely responsible for any direct or indirect damage or harm that may be caused to FLEBI as the party responsible for this website or to third parties if you complete any form with false data or data from third parties, causing deception, damage or harm.

Please let us know of any changes that may occur in the data provided by sending an email to legal@flebi.com

At FLEBI we store the user’s personal data on secure servers, protected against the most common types of attacks and located in Spain. However, given that there is no invulnerable technology, the user must also take the means at their disposal to maintain the security level of their data, by using strong passwords, periodically changing their passwords, avoiding using the same one in different accounts, as well as avoiding writing them down on any physical or unencrypted medium.

FLEBI COOKIE POLICY

The FLEBI SOLUCIONES S.L. team would like to inform you that we use cookies in order to facilitate the use and navigation through the website https://www.flebi.com.

WHAT ARE COOKIES?

A cookie is a file that is downloaded to the user’s computer or device when accessing a website in order to store and retrieve information about the user’s browsing habits or their equipment.

Cookies are not only for the benefit of companies, but also allow for the establishment of levels of protection and security, the collection of statistical and usually anonymous data, as well as the creation of advertising tailored to the interests of users.

TYPES OF COOKIES

Cookies can be classified according to different functions and parameters. Some of the most common classifications are:

Based on the TIME PERIOD that they remain activated on the device:

• • Session cookies: These are a type of cookies designed to collect and store data while the user is accessing a website. In other words, these cookies are stored on the user’s computer until the end of the browsing session.
• • Persistent cookies: these are cookies in which the data remains stored on the computer and can be accessed and processed for a period defined by the person responsible for the cookie, which can range from a few minutes to several years.

In attention to its PURPOSE:

• Analytics: collect information on the use of the website

• Social: those necessary for external social networks

• Affiliates: allow tracking of visits from other websites with which the website establishes an affiliation contract

• Advertising and behavioral: collect information about the user’s personal preferences and choices

• Technical and functional: these are strictly necessary for the use of the website and for the provision of the contracted service.

For your MANAGEMENT:

Own cookies: These are sent to the user’s terminal equipment from a computer or domain managed by the publisher itself and from which the service requested by the user is provided.

Third-party cookies: These are sent to the user’s terminal equipment from a computer or domain that is not managed by the publisher, but by another entity that processes the data obtained through the cookies.

WHAT COOKIES DO WE USE?

The cookies used on this website are the following:

COOKIE	RECEIVER	TYPE	PURPOSE	MORE INFORMATION	DURATION
cookielawinfo-checbox-analytics	FLEBI	Analytics	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Advertisement”.	Policy	session
cookielawinfo-checbox-functional	FLEBI	Functional	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Advertisement”.	Policy	Session
cookielawinfo-checbox-others	FLEBI	Others	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Advertisement”.	Policy	Session
cookielawinfo-checkbox-necessary	FLEBI	Technical	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Advertisement”.	Policy	Session
cookielawinfo-checkbox-performance	FLEBI	Analytics	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Advertisement”.	Policy	Session
viewed_cookie_policy	FLEBI	Technical	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.	Policy	Session
_ga; _gat; _gcl_au; _gid _fbp	FLEBI	Analytics	Analytics (identification, use and distinction of users.	Policy	1 hour to 2 years
Wp-wpml_current_language	FLEBI	Technical	Stores configuration preferences, such as preferred language,	Policy	Session
Ssupp.vid; ssupp.visits	FLEBI	Functional	For user identification	Policy	6 months
NID	GOOGLE	Analytics	It is used to remember your preferences on the website.	Policy	6 months
_GRECAPTCHA	GOOGLE	Functional	Used in forms to avoid SPAM	Policy	6 months
IDE	DOUBLECLICK.NET	Technical	They are used for the operation of Google services, such as reCaptcha and search and content sharing services.	Policy	1 year

USER OPTIONS

If you decide to change your preferences later through your browsing session, you can click on the “Privacy & Cookie Policy” tab on your screen. This will display the consent notice again, allowing you to change your preferences or withdraw your consent entirely. In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change your browser settings to block/delete cookies. For more information on how to manage and delete cookies, please visit https://policies.google.com/privacy?hl=en.

DEACTIVATION OF COOKIES

You can also disable and delete cookies, depending on the browser, in the following ways:

• Chrome. https://support.google.com/chrome/answer/95647?hl=es

• Firefox. https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-sitios-web-rastrear-preferencias?redirectlocale=es&redirectslug=habilitar-y-deshabilitar-cookies-que-los-sitios-we

• Explorer.https://support.microsoft.com/es-es/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

• Safari for IPhone IPad or IPod: https://support.apple.com/es-es/HT201265

• Opera: https://help.opera.com/es/Windows/11.50/es-ES/cookies.html

• Safari for MAC https://support.apple.com/es-es/guide/safari/sfri11471/mac

• Windows 10: Microsoft Edge. https://support.microsoft.com/es-es/help/17442/windows-internet-explorer-delete-manage-cookies

You can also disable Google Analytics cookies by installing the following plugin: https://tools.google.com/dlpage/gaoptout/?hl=es

DISCLAIMERS

At FLEBI we cannot and do not assume any responsibility for the content, veracity or updating of the privacy policies that third parties mentioned in this cookie policy may have.

Web browsers are responsible for storing cookies, and it is from these sites that you must exercise your right to delete or deactivate them, therefore, we cannot guarantee correct behavior.

RIGHT TO MODIFY COOKIE POLICIES.

FLEBI reserves all rights to modify its privacy policy without prior notice.