PRIVACY POLICY AND DATA PROTECTION

1.- IDENTIFICATION DATA AND OWNERSHIP OF THE WEBSITE

The purpose of this Privacy Policy is to inform you, in accordance with the provisions of EU General Data Protection Regulation 2016/679, Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, and its national and European implementing regulations, how we obtain, process and protect the personal data you provide or that we collect, through forms or cookies, on our website https://feebbo.com/, hereinafter "the website", so that you may freely and voluntarily decide whether you wish us to process them.

The website is owned by Feebbo Solutions, S.L.U., hereinafter FEEBBO, with Tax ID B13515622, and registered address at Calle Serrano, 42-4ºA, 28001 Madrid (Spain), registered in the Commercial Registry of Madrid, Volume 42685, Folio 126, Sheet M754918, Entry 2nd.

2.- DATA CONTROLLER

The company responsible for the processing of your data is Feebbo Solutions, S.L.U., hereinafter FEEBBO, with Tax ID B13515622, and registered address at Calle Serrano, 42-4ºA, 28001 Madrid (Spain).

3.- DATA PROTECTION OFFICER

The Data Protection Officer (DPO) is the person designated by FEEBBO to oversee compliance with applicable data protection legislation. If you consider that your data protection rights and freedoms have not been respected, you may contact the Data Protection Officer at the email address dpo@feebbo.com, or by post to the attention of the DPO, Calle Serrano, 42-4ºA, 28001 Madrid (Spain).

4.- CONTENT AND ACCEPTANCE OF THE PRIVACY POLICY

This Privacy Policy aims to inform you of the way in which personal data accessed through the completion of the form on the website is collected, processed and protected, so that you may freely and voluntarily decide whether you wish to provide your personal data through the form provided for that purpose. In addition, FEEBBO will provide you with the appropriate technical means so that, prior to completing the personal data, you may access this Privacy Policy and any other relevant information on Personal Data Protection.

Accessing and using the website implies that you fully accept and undertake to comply with the terms and conditions set out in this Privacy Policy, as well as the provisions contained in the Legal Notice, both documents together constituting the applicable Legal Texts. You can find the corresponding links at the bottom of the registration form provided.

We remind you of the importance of carefully reading these Legal Texts on each occasion you intend to use the website, as they may be modified due to updates, legislative and jurisprudential requirements, or business needs.

This Privacy Policy shall be valid for personal data obtained through the website and does not apply to third-party websites linked from https://feebbo.com/, nor to other websites owned by FEEBBO. Therefore, we ask that you carefully read the privacy policies of each of those websites you visit.

5.- CONTROLLER OF FILES AND COLLECTION OF PERSONAL DATA

FEEBBO, through the form made available on the portal, may collect the personal information detailed below in order to tailor commercial offers to your requests and provide you with a more personalised and effective service:

Identification data: name and surname.
Contact data: email address, telephone number.
Postal data: full postal address.
Sociodemographic data: gender and date of birth.

and all data necessary for the service request. These data are necessary to allow registration, management of the user account and participation in the activities and services offered by FEEBBO. These data will be incorporated into the personal data files owned by FEEBBO, which guarantees the confidentiality of the personal data provided and compliance with all applicable regulations. FEEBBO is therefore the data controller.

FEEBBO does not collect particularly sensitive data within the meaning of Article 9 of the GDPR (such as ideology, health, sexual orientation, trade union membership or biometric data). FEEBBO does not process geolocation data. At no time are data collected or processed that would allow precise geographical identification of the user, either through the website or through devices associated with browsing. The data provided will be processed in accordance with the provisions of this policy and will not be used for purposes incompatible with those informed, except where required by law or court order.

All fields in the form are mandatory, so that omitting any of them may, by the very nature of the service provided, result in the inability to process your request to participate in contests and promotions. Furthermore, by clicking the "Register" button, or equivalent, incorporated in the registration form, you declare that the information and data provided therein are accurate and truthful. To ensure that the information provided is always up to date and error-free, you must notify us as soon as possible of any changes to your personal data, as well as any corrections of inaccurate data if you detect any.

In the context of the processing described below, you may provide personal data relating to third parties. In this respect, it is your responsibility to inform the third party whose data you are going to provide us with of this circumstance, as well as to have previously obtained the express consent of that person for their data to be processed by FEEBBO, having previously informed them of everything provided for in Article 14 of the General Data Protection Regulation. FEEBBO guarantees its commitment to compliance with applicable regulations on data protection and the information society.

6.- WHAT DATA WE COLLECT AND PURPOSES OF PROCESSING

Through the website https://feebbo.com/ we collect contact data (name, surname, telephone, email address and postcode), date of birth (to verify majority), gender, and all data essential and dependent on the service request of those users who wish to benefit from the services offered on the websites and wish to receive commercial information about products and services that may be of interest to them.

Specifically, the purposes of data collection and processing are:

Managing user requests made through the website, whether through the contact form, any other type of online form, or via an email request. These requests may consist of:
- Management of service requests, order processing, response to commercial information requests.
- Participation in surveys and market studies, including the management of associated incentives or remuneration.
- Job applications.
- Subscription to FEEBBO newsletters, bulletins or blog.
- Any other interaction between the website user and FEEBBO aimed at satisfying the user's needs.
Processing your data for commercial purposes: Sending commercial communications about FEEBBO's own products or services or those of third parties, provided you have consented to the relevant personal data processing and given your express consent in accordance with applicable law, whether by ordinary or electronic means, in accordance with the provisions of the "Commercial Communications" section or similar.
Transfer of data to third parties: Communicating personal data to partner entities or third parties for commercial purposes, only in cases where the data subject has previously given explicit consent.
Personalisation of experience: Adapting the content displayed on the website to the user's interests or preferences, including the presentation of advertising or employment-related content, where relevant and non-intrusive.
User support: Managing queries, complaints or incidents related to the operation of the website, published legal texts or any aspect linked to the processing of personal data, ensuring adequate and legally compliant service.

The data collected for the purposes described above will be processed on the basis of the consent you have provided. You may withdraw such consent at any time, although this will not affect the lawfulness of processing carried out prior to its withdrawal. Providing the data is voluntary, but failure to do so will mean we cannot process your request or respond to the relevant query. Therefore, the communication of your personal data for these purposes is a necessary requirement for us to be able to attend to requests submitted through these channels.

7.- RETENTION

FEEBBO will retain the personal data of data subjects only for as long as strictly necessary to fulfil the specific purposes for which they were collected, in accordance with the principles of storage limitation and proactive accountability set out in Article 5(1)(e) of the GDPR.

Once these purposes have been fulfilled, the data will be duly blocked, in accordance with the provisions of Article 32 of the LOPDGDD, remaining at the exclusive disposal of the competent authorities, in particular the Spanish Data Protection Agency (AEPD), during the legally required periods depending on possible liabilities arising from processing. As a general rule, this blocked retention period will be five (5) years.

After this blocking period, the data will be securely and permanently deleted through procedures that guarantee their irreversible destruction or anonymisation.

8.- COLLECTION OF PERSONAL DATA

In compliance 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, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR), and Spanish data protection regulations, we inform you that data collected through the website data collection form will be incorporated into FEEBBO's automated personal data files, which guarantees the confidentiality of personal data provided and compliance with all applicable regulations.

By submitting the data requested in the registration form, you declare that the information and data provided therein are accurate and truthful. To ensure that the information provided is always up to date and error-free, you must notify us as soon as possible of any changes to your personal data, as well as corrections of inaccurate data if you detect any.

In the context of the processing described in this Privacy Policy, you may provide personal data relating to third parties. In this respect, it is your responsibility to inform the third parties whose data you are providing us with, and, where necessary, to obtain their express consent to provide us with such information.

9.- LEGAL BASIS FOR DATA PROCESSING

The data collected for the described purposes and the profiles drawn up in connection with automated individual decisions will be processed on the legal basis of the free, informed, specific and unambiguous consent given for each of the described purposes. Withdrawing consent is as easy as giving it. Therefore, if you change your mind and do not wish to receive job offers or commercial communications, you may withdraw your consent at any time, although this will not affect the lawfulness of processing carried out prior to its withdrawal.

FEEBBO will only process users' personal data when there is a valid legal basis pursuant to Article 6 of the General Data Protection Regulation (GDPR). The bases that legitimise the processing described in this policy are as follows:

Performance of a contract or application of pre-contractual measures (Art. 6.1.b GDPR): To manage requests submitted by the user through the website, including participation in surveys and order processing.
Consent of the data subject (Art. 6.1.a GDPR): For sending commercial communications, subscription to newsletters, personalisation of content or transfer of data to third parties for commercial purposes. The user may withdraw their consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
Compliance with legal obligations (Art. 6.1.c GDPR): In cases where data processing is required by legal provisions of a tax, accounting or data protection nature, among others.
Legitimate interest of the controller (Art. 6.1.f GDPR): To ensure website security, prevent fraud, carry out aggregated statistical analyses, improve service quality, and manage general interactions not linked to strictly commercial purposes, provided the fundamental rights and freedoms of the data subject do not prevail.

In all data collection forms, the mandatory or optional nature of the fields requested will be expressly indicated. Failure to complete mandatory fields may prevent the proper processing of the request or access to certain services.

10.- COMMERCIAL COMMUNICATIONS

We hereby inform you that by checking the box stating "I wish to receive from FEEBBO, via electronic or postal means or any other medium, commercial information, offers, and promotions from third-party companies belonging to the sectors identified in the Privacy Policy" included in the data collection form, you expressly consent to receiving commercial communications regarding products and/or services offered by third parties operating in various sectors of activity (telecommunications, employment and training, IT and technology, leisure and entertainment, gastronomy and food, games and casinos, furniture and home appliances, antiques, decoration and interiors, organizations and associations, auctions, DIY, energy, pets, financial services and insurance, real estate offers, motor vehicles and automotive, men's/women's products, fashion, energy sector, travel and tourism, children's products, music and books, health and wellness, society, sports, legal sector, claims management, wholesale tobacco trade, claims management companies authorized by the FCA for vehicle financing claims) selected by FEEBBO, in accordance with your behavior and preferences through automated individual decision-making processes, including profiling.

Commercial communications may be sent via email, telephone call, SMS, instant messaging applications, social media, push notifications, or any other equivalent electronic communication medium, as well as by postal mail or direct mailbox delivery, in order to provide you with information about products and/or services that we believe may be of interest to you.

Profiling, carried out through the analysis of automated individual decisions, consists of the use of your personal data to evaluate certain personal aspects, such as personal preferences, interests, behavior, location, and tastes. The logic applied to generate these profiles involves the use of statistical procedures. The consequence of this data processing activity through profiling is the sending of personalized communications tailored to your interests, containing content related to the aforementioned sectors.

If at any time you no longer wish to receive commercial communications, you may revoke your consent by submitting the relevant request to Feebbo Solutions, S.L.U., at Serrano Street, 42-4th Floor A, 28001 Madrid (Spain), or by sending an email to dpo@feebbo.com, attaching a copy of a document that verifies your identity (such as a National ID Card, residence permit, etc.), or by using the opt-out link provided for this purpose in the commercial communications you receive. Your request will be processed as promptly as possible, within the timeframes established by applicable data protection legislation.

11.- TRANSFER OF PERSONAL DATA

By ticking the box "I accept that FEEBBO transfers my personal data to third-party companies related to the sectors of activity detailed in the Privacy Policy", you give your express consent for FEEBBO to provide your personal data to companies it collaborates with and their international partners, in order to guarantee the integrity and security of data processing activities, as well as for the prevention and detection of unlawful conduct and so that they may contact you by email, telephone call, SMS, instant messaging applications, social networks, push notifications, or any other equivalent electronic communication means, or by post or mailbox distribution, to send you information of interest relating to products and/or services of third parties belonging to different sectors of activity related to the sectors indicated in the "Commercial Communications" section or the service you have requested.

In the event that such companies process your personal data on behalf of and under the instructions of FEEBBO, and not for their own purposes, they will act as data processors, in accordance with Article 28 of Regulation (EU) 2016/679 and Organic Law 3/2018 of 5 December. In such cases, FEEBBO will ensure the execution of the corresponding data processing agreement, which will include the legally required obligations to ensure adequate protection of your personal data.

These third-party companies will process and retain personal data only for the time necessary to achieve the aforementioned purposes, in full compliance with applicable data protection laws and regulations, and on the legal basis of legitimate interests provided for in Article 6.1.f) of the GDPR. Information will be retained only for as long as strictly necessary, in accordance with applicable data protection and fraud prevention regulations.

In all cases, the processing carried out by these third parties is done in compliance with the GDPR, the LOPDGDD and other applicable regulations.

Data subjects may exercise their rights of access, rectification, erasure, restriction of processing, objection and data portability in accordance with Articles 15 to 22 of the GDPR. Any request must be addressed to the Data Protection Officer (DPO) of each third-party company specified in their privacy policies and also in the transferees annex indicated below.

In all cases, the consent given is free, specific, informed and unambiguous, and you may revoke it at any time, without retroactive effect, by writing to FEEBBO at the address indicated in this privacy policy or via email at dpo@feebbo.com.

You may consult the identity of the possible transferees of your personal data and their DPOs.

12.- COMMUNICATION OF PERSONAL DATA

For the correct provision of the services offered at https://feebbo.com/ and the maintenance of the relationship with you, the personal data previously provided in the registration form may be processed by third parties.

The personal data you provide may be communicated to FEEBBO's various collaborators and service providers, as data controller, who will process the personal data as data processors on behalf of and for the account of FEEBBO, with the purpose of guaranteeing the services provided by said controller and complying with the obligations arising from applicable regulations, in accordance with the consent given.

In any of the cases described, we inform you that the computer servers of said service providers may be located in countries outside the European Union, where, if the level of privacy protection is not equivalent to European and national personal data protection regulations, FEEBBO, as data controller, will adopt the appropriate and necessary measures to best safeguard the rights of data subjects and information security, based on the technical measures available at any given time, in accordance with Articles 44 et seq. of the GDPR. Furthermore, where access to data by third parties is necessary for the provision of any service subcontracted by FEEBBO, the necessary documents will be signed to guarantee the security of your personal data and the correct exercise of your rights.

13.- INTERNATIONAL TRANSFER OF PERSONAL DATA

In the context of the provision of our services, the management of our commercial relationships and the correct functioning of our operations, your personal data may be transferred to recipients located outside the European Economic Area (EEA), including, by way of example, providers of technological services, cloud infrastructure, analysis tools, or commercial partners established in the United States, United Kingdom, Australia, etc.

Such transfers are made exclusively when the recipient acts in compliance with contractual or legal obligations arising from commercial agreements entered into with our company, and always for the purposes specifically detailed in this Privacy Policy.

The lawfulness of these transfers is based on one of the following mechanisms provided for in Chapter V of Regulation (EU) 2016/679 (GDPR):

Adequacy Decisions: For those countries that have a European Commission Decision recognising an essentially equivalent level of protection to that of the EEA.
Appropriate Safeguards (Art. 46 GDPR): In cases where the destination country does not have an adequacy decision, transfers are based on the Standard Contractual Clauses (SCCs) approved by the European Commission through Decision (EU) 2021/914, or other recognised tools (Binding Corporate Rules, Codes of Conduct or Certification Mechanisms). Prior to the transfer, we carry out an assessment of the legal framework of the destination country and, where appropriate, apply complementary technical, contractual and organisational measures to ensure that your data enjoy a level of protection equivalent to that required in the EU.

In compliance with Article 13(2)(f) of the GDPR, you may access the updated list of countries with an adequacy decision on the European Commission's website, and request a copy of the Standard Contractual Clauses applicable to each transfer, as well as documentation on the supplementary measures adopted, by contacting our Data Protection Officer at dpo@feebbo.com.

These transfers do not imply any waiver of your rights as a data subject. You may exercise the rights of access, rectification, erasure, restriction, portability and objection in accordance with the GDPR and the LOPDGDD, without prejudice to the safeguards applicable in the destination country.

14.- SECURITY

FEEBBO has adopted the necessary technical and organisational measures to guarantee a level of security appropriate to the risk presented by the personal data processing it carries out, in accordance with Article 32 of the General Data Protection Regulation (GDPR). Evidence of this is the certification under the ISO/IEC 27001:2022 Information Security Management System standard.

In particular, mechanisms have been implemented to preserve the confidentiality, integrity, availability and resilience of processing systems and services, as well as protocols that allow the rapid restoration of availability and access to data in the event of a physical or technical incident. These measures have been selected taking into account the state of the art, the costs of implementation, the nature of the data processed and the risks identified.

Nevertheless, FEEBBO informs users that the transmission of information over open networks such as the Internet cannot be guaranteed as completely secure. Therefore, any communication of personal data through this channel is carried out under the exclusive responsibility of the data subject.

Once information is received, FEEBBO applies robust security controls to prevent unauthorised access, misuse, alteration or loss of personal data processed, and carries out periodic reviews of its security measures to adapt them to the evolving risks and available technologies.

In the event of a security breach affecting personal data, FEEBBO will activate its internal breach management protocol, assess the risk to the rights and freedoms of data subjects, and, where appropriate, notify the incident to the Spanish Data Protection Agency within a maximum of 72 hours. Where the risk is high, it will also directly inform those affected, clearly and promptly.

In addition, FEEBBO has internal information security policies that regulate in detail the procedures, controls and responsibilities in the processing of personal data. These policies are reviewed periodically and aligned with the principles of the GDPR, ensuring proactive and diligent management of data security.

15.- CONFIDENTIALITY

At FEEBBO we are aware of the importance of your personal data and treat them with absolute confidentiality, committing to keep them secret and guaranteeing the duty to safeguard them by adopting all necessary measures to prevent their alteration, loss, processing or unauthorised access, in accordance with our legal obligations as data controller of your personal data.

16.- MINORS

Minors may not participate in actions available through the website without the prior authorisation of their parents, guardians or legal representatives, who shall be solely responsible for all acts carried out through the website by the minors in their care, including completion of forms with the personal data of such minors and, where applicable, ticking the accompanying boxes. In this respect, and insofar as FEEBBO has no capacity to check whether users are minors, parents and guardians are advised to enable the necessary mechanisms to prevent minors from accessing the website and/or providing personal data without their supervision, and FEEBBO accepts no responsibility in this regard.

17.- EXERCISE OF RIGHTS

In accordance with Articles 12 to 22 of the General Data Protection Regulation (GDPR), data subjects may exercise the following rights before FEEBBO in relation to the processing of their personal data:

Right of access: Obtain confirmation as to whether or not FEEBBO is processing personal data concerning them, and to access such information.
Right of rectification: Request the modification of inaccurate or incomplete data, providing supporting documentation when necessary.
Right of erasure (right to be forgotten): Request the deletion of data when the purpose for which they were collected has ceased to exist, consent has been withdrawn, or the data subject objects to processing, among other legally provided cases.
Right to restriction of processing: Request that their data be retained by FEEBBO solely for the purpose of establishing, exercising or defending legal claims, in legally provided cases.
Right to object: Object at any time, on grounds relating to their particular situation, to the processing of their data where such processing is based on the legitimate interest of FEEBBO.
Right to data portability: Request the transmission of their data to another controller, where processing is based on consent or a contract and is carried out by automated means.
Right to lodge a complaint with a supervisory authority: If you consider that the processing of your data infringes applicable regulations, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) through its website www.aepd.es.
Right to withdraw the consent given.
Right not to be subject to automated decisions, including profiling.

Any person has the right to obtain confirmation as to whether or not FEEBBO is processing personal data concerning them. Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data or, where applicable, request their erasure when, among other reasons, they are no longer necessary for the purposes for which they were collected. In certain circumstances, you may request restriction of the processing of your data, in which case FEEBBO will only retain them for the establishment, exercise or defence of legal claims. In certain circumstances, and on grounds relating to your particular situation, you may object to the processing of your data. In this case, FEEBBO will cease to process the data, except for legitimate compelling reasons, or the establishment, exercise or defence of legal claims.

To exercise any of the above rights, or to make any enquiry relating to the protection of your data, without affecting the lawfulness of processing based on consent prior to its withdrawal, you may contact FEEBBO's Data Protection Officer by post at Feebbo Solutions, S.L.U., Attn: Data Protection Officer, Calle Serrano, 42-4ºA, 28001 Madrid (Spain), or by email to dpo@feebbo.com.

FEEBBO will respond to all requests within the maximum period established by regulations, and may request additional information to confirm your identity when necessary.

If you consider your rights regarding the protection of your personal data to have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if you consider that the processing of your personal data infringes applicable regulations (www.aepd.es).

In compliance with Article 21 of Law 34/2002 on information society services and electronic commerce, if you do not wish to receive further information about our services, you may unsubscribe at the entity's email address, dpo@feebbo.com, stating "Do not send emails" in the subject line, or through the links provided in the communications you receive.

18.- UPDATE

This Privacy Policy may be updated, so it is necessary for you to review this policy periodically and if possible each time you access the website, in order to be adequately informed about the type of information collected and its processing. You can find the Privacy Policy, together with the Legal Notice and legal texts, at the bottom of the website.

19.- CONTACT

To resolve any queries related to this Privacy Policy, you may contact FEEBBO via the email address info@feebbo.com.

20.- APPLICABLE LAW

The applicable law in the event of a dispute or conflict of interpretation of the terms comprising this Privacy Policy shall be Spanish law.

This Privacy Policy was last updated on 1 January 2026. In order to ensure compliance with personal data protection regulations, FEEBBO has received legal advice from the specialist firm Vázquez Legal, S.L.P.U.

21.- DATA PROCESSING USING ARTIFICIAL INTELLIGENCE

We inform users that some of the processing carried out by FEEBBO may incorporate artificial intelligence (AI) components, used for specific purposes such as improving our services, data analysis or personalisation of the user experience.

Under no circumstances will exclusively automated decisions be made that produce legal effects or significantly affect the data subject, without significant human intervention, in accordance with Article 22 of the General Data Protection Regulation (GDPR). Furthermore, transparency in the operation of the AI systems used is guaranteed, providing clear information about the logic applied, its purpose and the anticipated consequences of the processing.

AI-based processing complies with the principles of the GDPR, especially those of lawfulness, fairness, transparency, minimisation, accuracy and security, and is subject to impact assessments where there is significant risk to the rights and freedoms of individuals. FEEBBO has adopted appropriate technical, security and organisational measures to ensure that such processing complies with applicable data protection regulations and the ethical principles applicable to these technologies.

Data subjects may at any time exercise their rights of access, rectification, erasure, objection, restriction, portability and the right not to be subject to automated decisions without human intervention, by contacting the DPO at dpo@feebbo.com or at the postal address Calle Serrano, 42-4ºA, 28001 Madrid (Spain).

The AI processing carried out by the Data Controller complies with the guidelines set out by the AEPD in its guide Adaptation of the GDPR to processing incorporating Artificial Intelligence.