Privacy Policy
LUZIA'S BASIC INFORMATION ON PERSONAL DATA PROTECTION
PERSON IN CHARGE OF THE TREATMENT
FACTORÍA ELCANO S.L.U. CIF nº: B13883186, with address in Madrid (Spain), at calle de Manzanares, 4, (CP-28005). Hereinafter, "Luzia".
PURPOSE OF PROCESSING AND STORAGE
The purpose will be the proper organization and/or provision and/or dissemination and/or communication and/or promotion of the services offered through WhatsApp, Telegram, the mobile application of the virtual assistant called Luzia (The Application) and those others found on the website luzia.com. The personal data processed will be retained for as long as the holder thereof remains linked to our Luzia service for: reasons of use of The Application, contractual relationship, as a contact or legitimate reasons of the responsible party and as long as their deletion is not requested by the interested party; in any case they will be retained as long as necessary for reasons of compliance with legal obligations.
Once the reason for which the data were collected or accessed has concluded, they will be deleted in accordance with the provisions of the regulations on the protection of personal data, which will imply, where appropriate, their blocking without access, so that they can only be available at the request of the relevant authorities with powers to require access (e.g. law enforcement agencies, judges and courts) and during the period of limitation of any actions that may arise; after that period, they will be completely deleted.
LEGITIMACY OF THE TREATMENT
Depending on the different types of data processing required according to the purpose, the basis of legitimacy will be:
- By prior and unequivocal consent of the interested party;
- By contractual relationship;
- For legitimate interest of the data controller;
- For compliance with a legal obligation;
RECIPIENTS OF CENSIONS OR TRANSFERS
Certain personal data necessary to provide the services offered by Luzia may be shared with:
- Our suppliers, when required by the activity, in which case we will inform the recipients, the purpose and the time of conservation of your data.
- Law enforcement agencies, judges and courts, when required in compliance with a legal obligation.
Personal data is processed and hosted on servers located within the European Economic Area (EEA).
RIGHTS OF INTERESTED PARTIES
The holders of personal data have the right to exercise at any time and free of charge the right to request: access, rectification, deletion of personal data that we process, limitation or opposition to its processing, processing and portability of the same, as well as not to be subjected to automated decision making.
To revoke your consent or exercise your rights, you must send a letter requesting the exercise of the specific right, addressed to the Data Controller, which can be accessed by sending an e-mail to the following address: gdpr@luzia.com. We may take such reasonable measures as we deem necessary to verify the identity of the owner exercising any of the rights indicated.
ORIGIN OF THE DATA
Directly by the interested party.
ADDITIONAL INFORMATION
If you have any doubts, questions or comments regarding the processing of your personal data, please send them to gdpr@luzia.com.
More information on how we process personal data is available in the following section of our privacy policy.
You can also consult information on data processing and data protection at the AEPD address. https://www.aepd.es/.
Privacy Policy
In accordance with the provisions of 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 (hereinafter "General Data Protection Regulation or GDPR") and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, we inform you of the following:
At Luzia (our virtual assistant or the Application), accessible from www.luzia.com, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains information about what data is collected and recorded by LUZIA and how we use it. If you have additional questions or require more information about our Privacy Policy, please do not hesitate to contact us.
This Privacy Policy applies to our online activities and is valid with respect to information we share with or collect from visitors to our websites and the Luzia application.
This Privacy Policy also describes how Luzia processes personal data and other information through its Application (the "Application") by listing the types of information Luzia collects, how that information is used and Luzia's sharing practices.
By using our website, or our virtual assistant, you accept our Privacy Policy and agree to its terms.
Processing of Personal Data
Processing of personal data" means - in accordance with the GDPR - any operation or set of operations performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure
by transmission, dissemination or otherwise making available, comparison or combination, restriction, erasure or destruction.
Identification of the person responsible for the processing of personal data
- FACTORÍA ELCANO, S.L.U.
- VAT NUMBER: B13883186
- Registered office: in Madrid (Spain), at calle de Manzanares, 4, (CP-28005)
- E-mail: contacto@luzia.com
What is the basis of legitimacy for the processing of personal data?
Depending on the purpose for which the processing of your personal data is intended, it will be required to have a type of data, which may lead us to perform any of the actions listed above. In such cases, the basis of legitimacy of such processing may be:
- Consent of the data subject: When required, we will ask for your prior and unambiguous consent. For example, through the contact form on our website that allows you to give your explicit consent.
- The maintenance of the business, contractual, administrative management or other relationship that we may maintain with the interested party.
- Compliance with legal requirements or information required by law enforcement or judicial authorities.
- Our legitimate interest in analyzing the use of the virtual assistant, the website, our social networks, blogs, platforms, their functionalities and/or services; the protection of our interests and defense of rights against third parties in case of controversy or third party claims, and in general, the development of the service and management of the services offered by Luzia or our website.
- Our legitimate interest to communicate or notify you of information with promotional content concerning Luzia, as well as promotions and offers about its activities or services. For example: our contests.
- Our legitimate interest in ensuring the security of our virtual assistant, website, social networks, blogs, platforms, communications and systems, to prevent or detect fraud, security incidents or other crimes.
Information we collect
The personal information requested from you and the reasons for the request will be clearly explained to you at the time you provide your personal information. If you contact us directly, we may receive additional information about you, such as your name, email address, telephone number, the content of the message and/or attachments you send us, and any other information you choose to provide. When you register for an account, we may ask for your contact information, such as your name, company name, address, email address and phone number.
We collect the following types of information when you use our Application which include: pages and files accessed; time of access; browser version; operating system; device ID; previously visited pages (if you access our Application through a link); IP address; application information; mobile device information; session ID; and cookies.
We collect the phone number and nickname (name or phrase or emoji) that you have set up on that platform to identify yourself and any information you submit through the chat functionality of the Application to respond to your inquiries. This functionality uses some automated processes to evaluate how we can best support your requests. Note that the conversations will be anonymized and encrypted with double encryption process and unlinked from the two previous User data, we can save an extract of the conversation to personalize future interactions.
Finally, we emphasize and emphasize the fact that the data that we may request, in general, are necessary to fulfill the purposes of our services, therefore, if they are not provided or not done correctly, we will not be able to meet your requests.
How we use your information
We use your information for the following purposes:
- to provide and improve our Application;
- to monitor interactions with our emails;
- to conduct surveys, contests, etc;
- to protect our interests or the interests of third parties;
- to maintain and improve the security of our Application;
- to improve our service;
- to provide you with the service you requested;
- to prevent abuse of our Application;
- to comply with our legal obligations;
- to communicate with you;
- for analysis and advertising purposes;
- to perform or enforce our agreements;
- to carry out recruitments;
- for load distribution and optimization of our Application;
- to provide customer support in connection with our products;
- for any other purpose with your consent.
We are not responsible for the privacy practices of any platform, website or application not controlled by us. In addition, use of the Application is prohibited in territories where any of our suppliers is prohibited.
We disclose information
Personal data may be communicated to third parties, provided that this communication responds to a need for the development of the legal relationship to be established, whether derived from a legal or contractual obligation, or from your prior consent. For example:
- to a buyer or other successor in the event of a merger, spin-off, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets; if we believe disclosure is necessary or appropriate to protect our rights, property or interests, our investors or others;
- to contractors, service providers and other third parties that we use to support our Application; currently our suppliers include WhatsApp LLC, Telegram, OpenAI and Stability AI, but they do not access personal data from the Application that we have shared with them.
- to fulfill any purpose for which it was provided to us;
- for any other purpose you are informed of when you provide the information to us;
- to comply with any court order, law or legal process, including responding to any governmental or regulatory request;
International data transfer
For the performance of certain processes, e.g. data storage in cloud systems, personal data is processed and hosted on AMAZON WEB SERVICES servers that are located within the territory of the European Economic Area (EEA) - thus not having the status of international data transfer under GDPR.
Retention of personal data
Personal data provided is processed and retained to the extent necessary to maintain the purpose for which it was collected or for as long as necessary to fulfill our contractual or legal obligations or any other permitted purpose for which we have collected it, including the prevention of fraud or security incidents. Upon expiration of the applicable retention period, we take steps to delete the information.
Cookies and Web Beacons
Like any other website, luzia.com uses cookies and web beacons. These tools are used to collect information about visitors, including preferences and which pages of the website the visitor accessed or visited. The information may be used to optimize the user experience by customizing the content of our website, for technical functions of operation or for the analysis of information about the navigation on the same, depending on the type of browser of visitors and / or other information. For more information you can consult our Cookies Policy section.
Log files
Luzia.com follows a standard procedure of using log files. These files record visitors when they visit websites. All hosting providers do this and it is part of the hosting services statistics. The information collected by the log files includes Internet Protocol (IP) addresses, browser type,
Internet Service Provider (ISP), time stamp, referring/exit pages and possibly the number of clicks. This data is not linked to personally identifiable information. The purpose of the information is to analyze trends, administer the site, track users' movement around the site, and gather demographic information.
For more information, please see our Cookie Policy section.
Personal data protection rights
We want to ensure that you are fully informed of all your personal data protection rights. Each user has the right to the following:
- Right of access: you have the right to request copies of your personal data.
- Right to Amend: You have the right to request that we correct any information that you believe is inaccurate. You also have the right to request that we complete information that you believe is incomplete.
- Right of erasure: you have the right to request that we delete your personal data, under certain circumstances.
- Right to restrict processing: you have the right to request that we restrict the processing of your personal data in certain circumstances.
- Right to object to processing: you have the right to object to the processing of your personal data, in certain circumstances.
- Right to data portability: You have the right to request that we transfer data we have collected to another organization, or directly to you, in certain circumstances.
If you make a request, we have one month to respond. If you wish to exercise any of these rights or revoke your consent, please contact us at (gdpr@luzia.com). We may take such reasonable steps as we deem necessary to verify the identity of data subjects who exercise the request for any of these rights, for example, requesting a copy of a valid identity document.
Information for children under 18 years of age
Luzia is a service only for people over 18 years old. Another of our priorities is the protection of children while using the Internet. We encourage parents and guardians to observe, participate in and/or supervise and guide their children's online activity. If you believe that your child under the age of 18 has provided this type of information on our website, we strongly encourage you to contact us immediately and we will make every effort to promptly remove such information from our records.
Safety measures
We respect your privacy and to ensure the confidentiality, integrity, availability and resilience of our systems and processing services, we adopt the necessary technical and organizational measures to ensure the security of the data and prevent its alteration, loss, unauthorized processing or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed.
Privacy Policy Version
The responsible for the Luzia Application, luzia.com website reserves the right to modify the content of this Privacy Policy, the modifications will be made public on this website. The relationship with users will be governed and will bind you according to the policies that are publicly exposed at the precise moment when the user accesses Luzia Application or luzia.com website.
Date of last update: September 2023.