The purpose of this policy is to inform data subjects about the different data processing activities carried out by this organization through its website that may affect their personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, and Organic Law 3/2018 of 5 December, on Personal Data Protection and Guarantee of Digital Rights.

1. IDENTIFICATION AND CONTACT DETAILS OF THE CONTROLLER

SEARCH ENGINE BUSINESS S.L., registered address: C/ Chile, 8 Oficina 208-209 (28290) Las Rozas, Madrid, Spain.

VAT number: B01764703

Phone: +34 919 049 229

Email: info@thinkia.com

DATA PROTECTION OFFICER (DPO)

SEGURIDAD Y PRIVACIDAD DE DATOS, S.L.

Phone: 963 122 868

Email: infodpo@forlopd.es

2. PURPOSES OF PROCESSING YOUR PERSONAL DATA

USERS/NAVIGATORS OF THE CONTROLLER’S WEBSITE

We will process the personal data provided for the following purposes:

• To handle requests, complaints, and incidents submitted through our contact channels on the website.
• To analyze user behavior on the website to detect potential cyberattacks.
• To comply with legal obligations directly applicable to and governing our activity.
• To protect and exercise our rights or respond to claims of any kind.
• Where applicable, to send commercial communications related to our products or services, and/or news or newsletters relevant to our sector. Refusal to authorize this will make it impossible for us to send such information.
• Where applicable, to manage your participation in contests or promotions organized by the entity. Refusal to authorize this will make participation impossible.
• Where applicable, to send satisfaction and/or quality surveys. Refusal to authorize this will make it impossible to assess the service provided.

3. LEGAL BASIS FOR PROCESSING

USERS/NAVIGATORS OF THE CONTROLLER’S WEBSITE

The legal bases for processing your data are:

• Consent: Provided for the purposes indicated above. Refusal to provide your personal data will make it impossible to process it for those purposes.
• Legal obligation: To comply with obligations applicable to the Controller. In this case, the data subject cannot object to processing.
• Legitimate interest: To protect our image, business, and operations by preventing cyberattacks on our website. In this case, the data subject cannot object to processing, but may exercise the rights recognized under the “Rights” section of this policy.

4. DATA RETENTION PERIODS OR CRITERIA

Personal data will be retained for as long as necessary to fulfill the purposes for which it was initially collected.

Once the data are no longer needed, they will be duly blocked and kept available, where applicable, for competent public administrations, courts, or the Public Prosecutor’s Office, during the limitation period of potential legal actions arising from the relationship with the client and/or as established by law.

5. AUTOMATED DECISIONS AND PROFILING

The website does not perform automated decision-making or profiling.

6. RECIPIENTS

During the data processing period, the organization may disclose your data to the following recipients:

• Judges and Courts.
• Law enforcement agencies.
• Other competent public authorities or bodies when the Controller has a legal obligation to disclose personal data.

7. INTERNATIONAL DATA TRANSFERS

In compliance with Regulation (EU) 2016/679 and Organic Law 3/2018, we inform you that, as a result of using certain service providers, the entity carries out the following international data transfers to recipients established outside the European Economic Area (EEA):

• Country: United States (U.S.)
• Purpose: Web hosting
• Type of data: Identifying data — IP address
• Safeguard: EU–U.S. Data Privacy Framework, Decision of 10 July 2023

8. SOCIAL NETWORKS

To involve you in our activities and keep you informed of our latest updates, we inform you that SEARCH ENGINE BUSINESS S.L. has profiles on social networks.

All users may join our social networks or groups. However, unless we request your data directly (e.g., through marketing campaigns, contests, or promotions), your data will belong to the respective social network. We therefore recommend that you carefully read their Terms of Use and Privacy Policies, and configure your privacy settings appropriately.

Below is the link to the privacy policy of the social network where we are active:

LinkedIn: https://es.linkedin.com/legal/privacy-policy

9. RIGHTS

Data subjects may request more information about how their personal data are processed and may, at any time and free of charge, exercise their rights of access, rectification, and erasure, as well as request restriction of processing, object to processing, request data portability (when technically feasible), or withdraw consent. They may also request not to be subject to a decision based solely on automated processing, including profiling.

Requests can be made using the forms provided by the organization, or by writing to the postal or email addresses indicated above. To verify identity, you may be asked to provide a valid ID or similar document, unless verification can be done by less intrusive means.

If you believe your rights regarding data protection have been violated, particularly if you have not received satisfaction in exercising them, you may file a complaint with the Spanish Data Protection Agency (AEPD) via its website www.aepd.es.

In compliance with Article 21 of Law 34/2002 on Information Society Services and Electronic Commerce, if you no longer wish to receive information about our services, you may unsubscribe by sending an email to info@thinkia.com with the subject “UNSUBSCRIBE.”

10. ACCURACY OF DATA

The data subject guarantees that the data provided are truthful, accurate, complete, and up to date, and undertakes to notify any changes via the contact channels indicated in Section 1 of this policy. The subject shall be liable for any damages, direct or indirect, resulting from failure to comply with this obligation.

If the user provides third-party data, they declare that they have obtained the consent of the data subjects and undertake to convey the information contained in this clause to them, releasing the organization from any liability arising from failure to comply with this obligation.

11. MODIFICATIONS AND UPDATES

This Privacy Policy may be modified or updated in accordance with legal requirements or to adapt to the guidelines of the Spanish Data Protection Agency (AEPD), or as a result of changes to our website. For this reason, we recommend that users review our Privacy Policy periodically.

If you have any questions about this policy, you may contact SEARCH ENGINE BUSINESS S.L. using the forms provided by the organization, or by writing to the postal or email addresses indicated above.