Privacy Policy
In accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), as well as in compliance with the provisions of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD), the following points related to the processing of personal data that the User voluntarily provides when accessing the website https://www.inheritans.com (hereinafter, the "Website" or "Web", interchangeably) are reported below.
1. DATA CONTROLLER
- Data Controller: YOSEYOMO, S.L. (hereinafter, "YOSEYOMO" or the "Company", interchangeably).
- Tax ID: B70933684
- Address: Avenida del Port, 49, 2, Camins al Grau, 46021 Valencia, Spain.
- Registration Data: Commercial Registry of Valencia, Volume 11555, Book 8833, folio 161, Sheet no V217888, first registration.
- Email: support@inheritans.com
YOSEYOMO will process the personal data voluntarily provided by the user (hereinafter, the "User") when accessing the Web. The User expressly consents that YOSEYOMO may process such data under the terms established in this Privacy Policy and for the purposes expressed below.
Before registering on the Website, Users must read and accept this Privacy and Data Protection Policy. By entering the email address and clicking the "Send code" button, the request will only be sent if the User has previously accepted the Privacy Policy.
2. ORIGIN, PURPOSE AND LEGAL BASIS
The personal data of the User, or of third parties, that are provided by the User, will be processed confidentially and will be incorporated into the corresponding processing activity of YOSEYOMO.
In case the User provides third party data, they must guarantee that they have consent to process such data.
The processing activities carried out by YOSEYOMO are the following:
| ACTIVITY: REGISTRATION IN INHERITANS | |
|---|---|
| ORIGIN | Data provided directly by the User when registering on the Web and creating their profile. |
| LEGAL BASIS | General Data Protection Regulation, in particular: Art. 6.1.a): consent of the data subject for one or more specific purposes.Art. 6.1.f): satisfaction of legitimate interests pursued by the data controller or by a third party. |
| TREATMENT PURPOSES | User identification to obtain access to Web services and manage registration and deregistration. |
| COLLECTIVE | Natural persons, including representatives of legal entities, Web users. |
| DATA CATEGORY | Name, surnames, ID/Passport/NIE, email and telephone. |
| RECIPIENTS | No transfer of data to third parties is foreseen without the unequivocal and informed consent of the User. |
| INTERNATIONAL TRANSFER | No international transfer of data is foreseen. |
| RETENTION PERIODS | Data will be retained until the User withdraws their consent or the purpose for which they were collected has ended and the relevant legal actions have prescribed, unless the data must be maintained due to a legal obligation. |
| ACTIVITY: SUBSCRIPTION PAYMENT | |
|---|---|
| ORIGIN | Data provided by the User when contracting the subscription through available payment methods. |
| LEGAL BASIS | General Data Protection Regulation, in particular: Art. 6.1.a): consent of the data subject for one or more specific purposes. Art. 6.1.b): performance of a contract (service subscription). Art. 6.1.c): compliance with a legal obligation applicable to the data controller; Art. 6.1.f): satisfaction of legitimate interests pursued by the data controller or by a third party. |
| TREATMENT PURPOSES | Collection and management of subscription, billing, payment tracking, prevention of non-payment and financial control. |
| COLLECTIVE | Registered users, whether individuals or representatives of legal entities requesting billing in the name of a company. |
| DATA CATEGORY | Name, surnames, email address, postal address, billing data (in case of being a company: company name, address, Tax ID), bank or card data, telephone. |
| RECIPIENTS | No transfer of data to third parties is foreseen with the unequivocal and informed consent of the User. |
| INTERNATIONAL TRANSFER | YOSEYOMO uses the Stripe payment gateway, operated by Stripe Inc., for the management of subscriptions and transactions derived from contracting Inheritans services. Stripe Inc., based in the US, participates in the EU-US Data Privacy Framework, which guarantees that international data transfers to this provider have an adequate level of protection in accordance with article 45 of the GDPR and the adequacy decision adopted by the European Commission. You can consult more information about Stripe's Terms and Conditions and Privacy Policy at the following links: https://stripe.com/legal and https://stripe.com/privacy. |
| RETENTION PERIODS | Data will be retained until the User withdraws their consent or the purpose for which they were collected has ended and the relevant legal actions have prescribed, unless the data must be maintained due to a legal obligation. |
| ACTIVITY: SENDING COMMERCIAL COMMUNICATIONS | |
|---|---|
| ORIGIN | From the User themselves through the registration form available on the Website |
| LEGAL BASIS | General Data Protection Regulation, in particular: Art. 6.1.a): consent of the data subject for one or more specific purposes. Art. 6.1.f): satisfaction of legitimate interests pursued by the data controller or by a third party. |
| TREATMENT PURPOSES | Sending promotions and commercial information about Inheritans services through electronic means (email, push notifications, SMS). Personalization of advertising according to User preferences. |
| COLLECTIVE | Natural persons, including representatives of legal entities, service users. |
| DATA CATEGORY | Email address. |
| RECIPIENTS | No transfer of data to third parties is foreseen, except legal obligation or prior unequivocal and informed consent of the User. |
| INTERNATIONAL TRANSFER | YOSEYOMO uses Klaviyo, operated by Klaviyo Inc., for the management of communications sent to users, derived from the subscription of Inheritans services. Klaviyo Inc., based in the US, participates in the EU-US Data Privacy Framework, which guarantees that international data transfers to this provider have an adequate level of protection in accordance with article 45 of the GDPR and the adequacy decision adopted by the European Commission. You can consult more information about Klaviyo's Terms and Conditions and Privacy Policy at the following links: https://www.klaviyo.com/legal and https://www.klaviyo.com/legal/privacy/privacy-notice. |
| RETENTION PERIODS | Data will be retained until the User withdraws their consent or the purpose for which they were collected has ended and the relevant legal actions have prescribed, unless the data must be maintained due to a legal obligation. |
| ACTIVITY: CONTACT OR ONLINE INQUIRIES | |
|---|---|
| ORIGIN | From the User themselves through email for communications with the YOSEYOMO team. |
| LEGAL BASIS | General Data Protection Regulation, in particular: Art. 6.1.a): consent of the data subject for one or more specific purposes. |
| TREATMENT PURPOSES | Attend and respond to inquiries requested by the User. |
| COLLECTIVE | Natural persons, including representatives of legal entities, Website users. |
| DATA CATEGORY | Email and subject, as well as the rest of the data that the User themselves indicates in the message body. |
| RECIPIENTS | No transfer of data to third parties is foreseen, except legal obligation or prior unequivocal and informed consent of the User. |
| INTERNATIONAL TRANSFER | No international transfer of data is foreseen. |
| RETENTION PERIODS | Data will be retained for the period strictly necessary to fulfill the purpose for which they were collected. In any case, the maximum retention period will be 1 year. |
| ACTIVITY: WEBSITE PROTECTION THROUGH RECAPTCHA | |
|---|---|
| ORIGIN | Data automatically collected when the User interacts with forms on the Website. |
| LEGAL BASIS | Art. 6(1)(f) GDPR - the controller's legitimate interest in preventing fraud, automated access, and bot attacks. The legitimate interest is based on the need to protect the integrity, availability, and security of the Website and users' data against automated attacks, fraud, and unauthorized access, and is considered to override the data subject's rights and freedoms, as the processing is limited and strictly security-oriented. |
| PURPOSES OF PROCESSING | To ensure website security, prevent automated submissions, fraud and abusive use of forms. |
| DATA CATEGORY | IP address, browser data, operating system, browsing behavior and other technical information necessary to detect automated activity. |
| RECIPIENTS | Google Ireland Limited, as the reCAPTCHA service provider. |
| INTERNATIONAL TRANSFER | Google may carry out international data transfers outside the European Economic Area. Such transfers are covered by the Adequacy Decision adopted by the European Commission under the EU-US Data Privacy Framework and by the corresponding contractual safeguards. |
| RETENTION PERIODS | Data are retained for the time strictly necessary for the purpose of security and fraud prevention. |
The User undertakes to enter real and truthful data. Likewise, they will be solely responsible for the damages that YOSEYOMO may suffer as a consequence of the lack of veracity, inaccuracy, lack of validity and authenticity of the data provided.
3. WHO IS YOUR DATA COMMUNICATED TO?
Data disclosure will only be carried out in situations where it is essential for compliance with legal obligations imposed on the Data Controller, to the extent that such transfer is imperative. Likewise, they may be transferred to adequately provide services, in which case prior information about the context of the transfer will be provided, within the limits established by law.
Except in the mentioned cases, the consent of the data subject will be required for the transfer of data to a third party.
4. THIRD PARTY PERSONAL DATA
The User may provide personal data of designated recipients so that YOSEYOMO can custody and, when the time comes, deliver posthumous content as indicated by the User. This data may include name, surnames, email, telephone and identification document (ID or equivalent).
YOSEYOMO will process the personal data of recipients solely for the provision of the Service, in particular to verify the User's death and deliver posthumous messages. The legal basis for processing is the legitimate interest of the controller (art. 6.1.f GDPR), derived from the User's request and strictly limited to said purpose.
Recipients will be informed of the processing when they receive the initial notification or communication, and must accept Terms and Conditions and this Privacy Policy. Recipients' data will be deleted once the purpose is fulfilled, or kept blocked for the time necessary to address possible legal responsibilities.
5. DESIGNATION OF TRUSTED PERSON AND DEATH VERIFICATION
The User may designate one or more trusted persons to communicate their death to YOSEYOMO and activate the delivery of posthumous messages. Each trusted person must expressly accept YOSEYOMO's Terms and Conditions and Privacy Policy, committing to provide the necessary documentation for confirmation of the User's death.
YOSEYOMO recommends that persons designated as trusted persons be legitimate heirs or legal representatives, as only these persons usually have access to the required documentation. Trusted persons must expressly accept Inheritans' Terms and Conditions and Privacy Policy to assume this function.
YOSEYOMO is not responsible for the designation of persons who cannot provide the necessary documentation nor guarantees the delivery of messages if verification cannot be performed.
The processing of this data is limited exclusively to death verification and content delivery, guaranteeing the confidentiality and security of data in accordance with the GDPR.
6. WHERE IS YOUR DATA STORED?
Users' personal data are stored mainly on servers located within the European Economic Area. However, certain technology providers used to deliver the service (such as payment, commercial-communications or bot-protection services) may involve international data transfers, always with the appropriate safeguards in accordance with the GDPR and, where applicable, under the EU-US Data Privacy Framework. YOSEYOMO guarantees that these servers comply with the applicable European data-protection regulations.
7. HOW IS YOUR DATA PROTECTED?
YOSEYOMO employs updated technologies in accordance with the current state of the art to safeguard your data and personal information. Technical and organizational measures have been implemented to ensure the protection of personal data, preventing its alteration, loss, improper processing or unauthorized access. These measures are adapted to the current technological state, the nature of the stored data and the risks to which they may be exposed.
8. PRINCIPLES OF VERACITY AND UPDATE
All information provided by the User must be accurate and truthful. For this purpose, the User is responsible for verifying the authenticity of all data provided when completing the corresponding forms. When registering or completing any form, the User must provide all data indicated as mandatory, ensuring that they are accurate and reflect reality. Any modification in their data must be notified to YOSEYOMO as soon as possible. At all times, the User assumes exclusive responsibility for false or inaccurate statements and for damages that may arise for YOSEYOMO or third parties due to the information provided. Failure to communicate or incomplete communication of mandatory personal data may result in the inability to offer the requested service.
9. WHAT RIGHTS DO YOU HAVE REGARDING DATA PROTECTION?
The General Data Protection Regulation grants various rights to the data subject regarding the processing of their personal data. Below, we provide information about each of these rights and indicate the channels through which you can submit, if applicable, the corresponding request:
| TYPE OF RIGHT | DESCRIPTION |
|---|---|
| DELETION | You will have the right to request the deletion of your personal data if any of the following conditions are met:
|
| ACCESS | You have the right to obtain confirmation about whether personal data concerning you is being processed and, if so, access the following information: the purposes of processing; the categories of data being processed; the recipients or categories of recipients to whom the data has been or will be communicated, and, if possible, the planned period of retention of personal data or, if not possible, the criteria used to determine that period. |
| RECTIFICATION | You have the right to correct inaccurate personal data concerning you. Considering the objectives of processing, you also have the right to complete incomplete personal data, including through an additional statement. To exercise this right, you must specify in your request which data you refer to and what correction we should make. Additionally, if necessary, you must attach supporting documentation of the inaccuracy or incomplete nature of the data subject to processing. |
| LIMITATION | You have the right to request limitation of processing of your data in the following circumstances:
|
| PORTABILITY | You will have the right to receive the personal data concerning you, which you have provided to the Company, in a structured, commonly used and machine-readable format, and to transmit it to another data controller without the Company preventing it, when processing is based on consent, and is carried out by automated means. When exercising your right to data portability, you will have the right for personal data to be transmitted directly from controller to controller when technically possible. This right to portability will not apply to processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority. The right to portability will not extend to data that the Company may have inferred from data derived directly from the use of the services provided. |
| OPPOSITION | You have the right to object to the processing of your personal data, including profiling, at any time. If you decide to exercise this right, the Company will stop processing your personal data, unless we can demonstrate compelling legitimate grounds for processing to prevail over your interests, rights and freedoms, or for the formulation, exercise or defense of claims. |
| AUTOMATED DECISIONS | The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects them. |
| CHANNELS TO MAKE THE EXERCISE OF THESE RIGHTS EFFECTIVE: | |
To exercise any of the rights mentioned in the previous sections, you can send an email to support@inheritans.com or send a letter to the address indicated in the first section.
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10. CHANGES TO THIS PRIVACY POLICY
YOSEYOMO reserves the right to modify this Privacy Policy to adapt it to legislative, jurisprudential or industry practice developments. In such cases, YOSEYOMO will communicate the changes made on this page with reasonable advance notice before they take effect.