I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, PingaOculto (hereinafter also referred to as the Website) undertakes to adopt the necessary technical and organisational measures, in accordance with the level of security appropriate to the risk of the data collected.

Laws included in this privacy policy

This privacy policy is adapted to current Spanish and European regulations on personal data protection on the internet. Specifically, it complies with the following regulations:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007, of 21 December, approving the Regulations implementing Organic Law 15/1999, of 13 December, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The entity responsible for processing the personal data collected on PingaOculto is: PINGOC NOW S.L., with Tax ID Number (NIF/CIF): B72491368 and registered in the Madrid Commercial Registry with the following registration details: Volume 44072, Folio 84, Section 8, Registration Page 777404, whose representative is: Carlos Company Torres (hereinafter, Data Controller). Their contact details are as follows:

Address: Calle de Francisco Zea 12, Local, 28028, Madrid, Madrid, Spain

Contact phone: +34 91 417 04 02

Contact email: ppgad@pucrs.br

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by PingaOculto through the forms on its pages will be incorporated and processed in our file in order to facilitate, expedite and fulfil the commitments established between PingaOculto and the User or to maintain the relationship established in the forms that the User fills out, or to respond to a request or query from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is kept specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights:

  • Principle of lawfulness, fairness and transparency: the User's consent will be required at all times, following fully transparent information on the purposes for which the personal data is collected.
  • Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
  • Principle of data minimisation: personal data collected will only be that which is strictly necessary in relation to the purposes for which it is processed.
  • Accuracy principle: personal data must be accurate and kept up to date.
  • Principle of storage limitation: personal data shall only be kept in a form that permits identification of the User for the time necessary for the purposes of its processing.
  • Principle of integrity and confidentiality: personal data will be processed in such a way as to guarantee its security and confidentiality.
  • Principle of proactive responsibility: the Data Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed by PingaOculto are solely identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the treatment of personal data

The legal basis for the processing of personal data is consent. PingaOculto undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. Withdrawing consent shall be as easy as giving it. As a general rule, withdrawal of consent shall not affect the use of the Website.

On occasions when the User must or may provide their data through forms to make enquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of these forms is mandatory because they are essential for the proper performance of the operation carried out.

Purposes of the treatment to which the personal data are destined

Personal data is collected and managed by PingaOculto for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or maintaining the relationship established in the forms that the latter fills out or to respond to a request or query.

Furthermore, the data may be used for commercial purposes of personalisation, operational and statistical purposes, and activities related to the corporate purpose of PingaOculto, as well as for the extraction, storage of data and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functioning and navigation of the Website.

At the time the personal data is obtained, the User will be informed of the specific purpose or purposes for which the personal data will be processed; that is, the use or uses that will be made of the information collected.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 6 years, or until the User requests its deletion.

When personal data is collected, the User will be informed of the period for which the personal data will be stored or, where that is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will be shared with the following recipients or categories of recipients:

Nicalia Internet S.L.U., with registered office at Calle Sant Marc 35, Canet de Mar, Barcelona, Spain.

Automattic Inc., located at 60 29th Street #343, San Francisco, CA 94110, United States

Stripe Payments Europe, Limited con domicilio en The One Building, 1 Grand Canal Street Lower, Dublín, Irlanda

PayPal (Europe) S.à r.l. et Cie, S.C.A., con domicilio social en 22-24 Boulevard Royal, L-2449, Luxemburgo.

Klarna Bank AB (publ) with registered office at Sveavägen 46, 111 34 Stockholm, Sweden

SendCloud B.V., with registered office at Insulindelaan 115, 5642 CV Eindhoven, Netherlands.

General Logistics Systems Spain, S.A., with registered office at C/Ingeniero Torres Quevedo, 1, 28022 Madrid, Spain.

DHL PARCEL IBERIA, S.L.U., with registered office at P.º Mikeletegi 65, 20009, San Sebastián, Guipúzcoa, Spain.

Sociedad Estatal Correos y Telégrafos, S.A., S.M.E., with registered office at Calle del Conde de Peñalver, nº 19, 28006 Madrid, Spain.

Google, Inc., located at 1600 Amphitheatre Parkway, Mountain View, California, CA 94043, United States

Meta Platforms Inc, located at 1 Meta Way, Menlo Park, California, 94025, United States

Pinterest Inc., located at 651 Brannan Street, San Francisco, CA 94107, United States

SENDINBLUE, located at 7 Rue de Madrid, 75008 Paris, France

OpenAI Ireland Limited, con domicilio social en 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublín 1, D01 YC43, Irlanda.

If the Data Controller intends to transfer personal data to a third country or international organisation, the User will be informed of the third country or international organisation to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission, at the time the personal data is obtained.

Personal information of minors

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, only persons aged 14 or over may give their consent for the lawful processing of their personal data by PingaOculto. In the case of minors under the age of 14, the consent of their parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

PingaOculto undertakes to adopt the necessary technical and organisational measures, in accordance with the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, since PingaOculto cannot guarantee the impregnability of the internet or the total absence of hackers or others who may fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a breach of personal data security is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach is any breach of security leading to the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or the unauthorised disclosure of or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform and ensure, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom the information is made available.

Rights derived from the processing of personal data

The User has the following rights over PingaOculto and may therefore exercise the following rights recognised in the GDPR and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights, before the Data Controller:

  • Right of access: Users have the right to obtain confirmation as to whether or not PingaOculto is processing their personal data and, if so, to obtain information about their specific personal data and the processing that PingaOculto has carried out or is carrying out, as well as, among other things, the information available about the origin of such data and the recipients of any communications made or planned.
  • Right of rectification: Users have the right to modify their personal data if it is inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure ("the right to be forgotten"): It is the User's right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its implementation, shall take reasonable steps to inform the controllers who are processing the personal data of the data subject's request to delete any links to such personal data.
  • Right to limitation of treatment: You have the right to restrict the processing of your personal data. You have the right to obtain restriction of processing when you contest the accuracy of your personal data; the processing is unlawful; the Controller no longer needs the personal data, but you need it for the establishment, exercise or defence of legal claims; and when you have objected to the processing.
  • Right to data portability: If the processing is carried out by automated means, the User shall have the right to receive their personal data from the Data Controller in a structured, commonly used and machine-readable format, and to transmit them to another data controller. Where technically feasible, the Data Controller shall transmit the data directly to that other controller.
  • Right of opposition: Users have the right to request that their personal data not be processed or that PingaOculto cease processing such data.
  • Right not to be the subject of a decision based solely on automated processing, including profiling: Users have the right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless otherwise provided by applicable law.

Therefore, the User may exercise their rights by writing to the Data Controller with the reference ‘GDPR - www.pingaoculto.com’, specifying:

  • Name, surname(s) of the User and copy of their ID card. In cases where representation is permitted, the person representing the User must also identify themselves by the same means, as well as providing proof of representation. A photocopy of the ID card may be replaced by any other legally valid means of proof of identity.
  • Request with the specific reasons for the request or information to be accessed.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that supports your request.

This application and any other accompanying documents may be sent to the following address and/or email:

Postal address: Calle de Francisco Zea 12, Local, 28028, Madrid, Madrid, Spain

E-mail: ppgad@pucrs.br

Links to third party websites

The Website may include hyperlinks or links that allow access to third-party websites other than PingaOculto, and which are therefore not operated by PingaOculto. The owners of such websites will have their own data protection policies, and they themselves will be responsible, in each case, for their own files and privacy practices.

Claims before the supervisory authority

If the User considers that there is a problem or breach of current regulations in the way in which their personal data is being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

Users must have read and agree to the conditions on personal data protection contained in this Privacy Policy, and must accept the processing of their personal data so that the Data Controller can proceed with such processing in the manner, during the periods and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

PingaOculto reserves the right to modify its Privacy Policy, at its own discretion, or due to a change in legislation, case law or doctrine of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. Users are advised to check this page periodically to stay informed of the latest changes or updates.

This Privacy Policy has been updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights.