This Privacy Policy was last revised on June 1, 2023
Welcome to the El Susurro platform, a Spanish corporation (“EL SUSURRO”, “we”, or “us”), social network, streaming platform, and digital performance platform consisting of the ELSUSURRO.COM website, services, software applications, embeddables, and syndicated widgets (the “EL SUSURRO Service”). EL SUSURRO values the privacy of users, subscribers, editors, members, and others who visit and use the EL SUSURRO Service (collectively or individually, “you,” “Yourself,” or “Users”).
We fully understand that you care about how we use your data. This Privacy Policy explains what information EL SUSURRO will collect from you when you use the EL SUSURRO Service, how the information will be used, and how you can control the collection, correction, and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. Capitalized terms not defined in this Privacy Policy are defined in our Terms of Service. This Privacy Policy is incorporated into and subject to EL SUSURRO’s Terms of Service.
By using the EL SUSURRO Service, you expressly agree to the information handling practices described in this Privacy Policy.
EL SUSURRO is committed to Data Protection compliance, in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016. You can consult it in this Privacy Policy. link.
Who is responsible for the processing of your data?
EL SUSURRO
Plaza Julio Gonzalez 8 bajos
08005 Barcelona (Spain)
NIF: 46228915-L
For what purposes will we process your personal data?
EL SUSURRO will process your data for the following purposes:
- Response to queries you send us via email or WhatsApp
- Sending newsletters announcing new features on our platform with the option to unsubscribe at any time.
- Sending WhatsApp communications in the event that you have provided your mobile phone number during the purchase process.
What is the legitimacy for the processing of your data?
The legal basis for the processing of your data is based on your express consent for each of the purposes, in accordance with the provisions of article 6.1. paragraph a) of Regulation (EU) 679/2016.
How long will your data be kept?
Your data will be kept for the period required by the purpose of the processing, as long as you do not revoke your consent or once the legal retention periods have ended.
To which recipients will we communicate your data?
ELSUSURRO.COM will not share the information you have provided to us, except to comply with a legal obligation or in the event that we have your express authorization.
We will not use your personal data for any purpose other than that stated in this privacy policy and in the consent collection forms. Therefore, all data transfers carried out will be made under the protection framework indicated by the Spanish Data Protection Agency, or as long as they are expressly consented to by the User and to countries whose security and confidentiality is guaranteed.
Will international data transfers be made?
EL SUSURRO does not plan to make international data transfers. If necessary, they will only be carried out to entities under the authorization of the US-European Union Privacy Shield agreement (more information: https://www.privacyshield.gov/welcome), or to entities that have demonstrated that they comply with the level of protection and guarantees in accordance with the parameters and requirements provided for in the current regulations on data protection, such as the European Regulation, or when there is legal authorization to carry out the international transfer.
What if a minor accesses it?
In general, the WEB ELSUSURRO.COM will not process personal information, with reliable knowledge, of minors under fourteen (14) years of age.
In the event that the WEB ELSUSURRO.COM, carrying out any control activity, discovers the involuntary collection of information regarding minors under 14 years of age, it will carry out all necessary measures that, as a service provider and data controller, it is obliged to undertake and thus be able to delete such information as soon as possible, except in those cases where, due to applicable legislation, it is necessary to retain it. In accordance with the provisions of the European Data Protection Regulation, those over 14 years of age are entitled to give their consent, except in those cases where the law requires the assistance of the holders of parental authority or guardianship for its provision.
Will you receive commercial communications and promotions?
The ELSUSURRO.COM website does not engage in SPAM practices, and therefore does not send commercial emails electronically that have not been previously requested or authorized by the User. Consequently, in each of the forms on the ELSUSURRO.COM WEBSITE, the User has the possibility of giving his/her express consent to receive said information, independently of the commercial information specifically requested.
What security measures will we apply?
The ELSUSURRO.COM website guarantees the appropriate degree of protection, adopting the technical and organizational measures necessary to guarantee security and which are legally necessary in order to avoid the loss, deterioration, misplacement or access by unauthorized third parties of the personal data collected here, thus keeping your data confidential. To do this, we apply security measures designed to protect your data, such as HTTPS. We periodically monitor our systems to detect possible vulnerabilities and attacks. However, we cannot guarantee the complete security of the information you send us if a leak occurs in any of our physical, technical or management security measures.
What rights can you exercise?
Once you, as a User of the ELSUSURRO.COM website, have provided us with your personal data, current legislation allows you, as the interested party of your data:
- Request access to personal data relating to the interested party, being able to know if we are processing their personal data and access their personal data
- Request rectification of data if it is inaccurate.
- Request deletion of their data to the extent that they are no longer necessary for the purpose that was communicated, or in the event that we no longer have the necessary legitimacy to continue with their treatment.
- Request limitation of their treatment, in some cases, so that we can temporarily suspend the treatment or that we keep them beyond the established time when you may need it.
- Oppose the processing of the information you have provided us, unless there are compelling legitimate reasons for the processing to prevail.
- Revoke consent for each specific purpose, without affecting the legality of the processing based on express consent.
- Request the portability of the data, which will be provided to you in a structured format, for common use or machine reading.
- To file a claim with the Spanish Data Protection Agency or competent control authority, if you believe that we have not attended to you correctly.
How can you exercise your rights?
EL SUSURRO has forms for exercising your rights, which you can request from us at mail@elsusurro.com or by post. If you prefer, you can use the forms prepared by the Spanish Data Protection Agency or the competent authority. These forms must be signed electronically or accompanied by a photocopy of a valid ID.
- By sending an email to the address: mail@elsusurro.com
- By sending a letter to the address: Plaza Julio Gonzalez 8 bajos, CP 08005 Barcelona, Spain
In the case of representation, you must attach a copy of the representative’s valid ID along with your application.
What is the established time to resolve the exercise of rights?
We will inform you of the actions arising from your request within one month, which may be extended by two more months in the case of particularly complex requests, and we will notify you of such extension within the first month. In those cases in which we do not respond to your request, we will inform you of this, giving reasons for our refusal within one month of its submission.
Can changes be made to the privacy policy?
ELSUSURRO.COM reserves the right to modify this policy to adapt it to new legislation or jurisprudence, as well as to industry practices. In such cases, the Provider will announce the changes introduced on this page with reasonable notice prior to their implementation.