Marfeel Solutions, S.L. is part of the IAB Europe Transparency and Consent Framework v.2.0 and complies with all policies and specifications. Marfeel Solutions, S.L is identified in said framework with the identification number 270.
Note for California consumers: Please note that if you reside in California, in addition to this policy, Annex 1 will apply to you. In this Annex you will find more information on the protection of your personal data in accordance with California regulations.
Note for users in Brazil: Please note that if you reside in Brazil, in addition to this policy, Annex 2 will apply to you. In this Annex, you will find more information on the protection of your personal data in accordance with the Brazilian Data Protection law.
Your personal data will be processed by the company MARFEEL SOLUTIONS, S.L. (“MARFEEL”), with NIF B-65.651.259 and whose contact details are the following:
- Address: Av Josep Tarradellas, 20-30 P.6 08029 - Barcelona
- Contact phone: 931 78 59 50
- Contact email: email@example.com
2.1. Minimum age. To provide us with your personal data, you must be at least 14 years old, although keep in mind that the services on this website are aimed at people of legal age.
2.2. Accuracy. When you provide us your data to use our services, you guarantee that the data and information provided is true, accurate, up to date and also that you own that information and it is not from third parties.
In addition, you must notify Marfeel of any change that occurs in the data provided, and you will be liable for the truthfulness and accuracy of the data provided.
2.3. Age and Accuracy Control. We reserve the right to verify, at any time, your age and your Personally Identifiable Information, even requiring an official document or equivalent procedure, if necessary; and, if in a fraud detection procedure it is proven or suspected that you are a minor, we will delete, temporarily deactivate and / or cancel your account.
The following section delineated how we process your personal information and provide all the relevant information related to your privacy:
Identifiable and contact information. We collect your identification data (name and surname) and email address, as well as any other that you voluntarily include in the communications you send us.
We may request additional information if it is necessary to fulfill your request or requirement.
Respond to your requests. The main purpose of the processing of this data will be to respond to your requests, answer your queries and / or provide you with the required information, as well as, where appropriate, follow up on your requests.
Customer service through chat on the Website is carried out using automatic software (chatbots), in order to be able to categorize the query and to be able to redirect it later to the appropriate person.
Improve customer service. All the information derived from the doubts, queries, and the advice given to the interested parties, as well as the way in which the requests are resolved, allows us to know how we provide our own customer service, and as result we are able to improve it.
After the retention period indicated below is over, the information collected is anonymized and used for the purposes of analyzing the most frequently asked questions through the chat and for the automation of the most frequent ones, prepare FAQS or be kept for statistical purposes to develop business strategies.
Consent. The data provided for the above purposes will be processed based on your consent given when, freely, you contact us through the means at your disposal to request information, or when you make a request.
Legitimate interest: The processing that we carry out with anonymized data for the improvement of customer service, will be processed based on our legitimate interest in knowing how we provide our own customer service, and being able to improve its quality. If you wish to obtain more information about the weighting that we have carried out, you can request it by writing to us at firstname.lastname@example.org.
Mandatory information will be indicated with an asterisk or in a similar way. Without this information it would not be possible to answer your questions or requests.
All your personal information will be processed during the time necessary to respond to your request and for the time necessary to follow up on them. Once this period is over, MARFEEL will block and store that information in accordance with the terms established in any specific legislation, to meet any liability and to demonstrate compliance with our obligations. From that moment on, MARFEEL will only process the information in an anonymized way, so it will not be possible to link the statistical information with the specific users to whom it refers.
We do not make any additional transfer to carry out this processing than those indicated in point 4. Who do we transfer your personal information to? Some channels through which you can contact us are managed by third parties, who act as Processors. You will find more information about how these Processor carry out their duties, in point 4 mentioned above
- Application form for job offers and CV submission in “Careers” section;
- Sending CV to email@example.com or other MARFEEL email addresses.
Identifiable and contact information. We collect your identifying information (name and surname), telephone number and email address.
Curricular, academic and professional information. By attaching your Curriculum Vitae (CV), we will be able to process the information related to your studies, training, academic experience and that which you have included in your professional documentation. We also request some additional information related to job positions (date of incorporation, references, expectations regarding salary).
In this sense, you should avoid providing us with sensitive information or that may reveal sensitive information such as ethnic origin, religious or philosophical beliefs, health data, sexual orientation, genetic information or union membership information.
Participate in our selection processes. In the event that you send us your CV, we will process your personal information to initiate, where appropriate, a selection process for a possible hiring and follow up on it (interviews, communications with the candidate, test, etc.).
Consent. The data provided for the above purposes will be processed based on your consent given when you sent us your CV to participate in our selection processes.
The information that you must provide in a mandatory way will be indicated with an asterisk or in a similar way. Without this information it would not be possible to start any selection processes.
We will process all your personal information during the selection process and / or, when there is no open selection process, for a maximum of 1 year since its collection, for possible future selection processes that may fit with your professional profile or the interests you have indicated.
We do not make any additional transfer to carry out this processing than those indicated in point 4. Who do we transfer your personal information to? Some channels through which you can contact us are managed by third parties, who act as Processors. You will find more information about how these Processors carry out their duties, in point 4 mentioned above.
- Registration form for the newsletter in other questionnaires
- Request of commercial information
- When there is a contractual relationship between the Parties
Identifying and contact information. To send commercial information by electronic means, we use the identifying data (name) and the contact information that you include in the corresponding form for registering in our commercial communications or those contact information (email and / or mobile phone) that we have due to our contractual relationship.
To send publications of interest and commercial communications: If you maintain a contractual relationship with us or have expressly requested this, we can send you, through electronic means, our newsletter, information of interest related to our activities and other commercial communications related to our products and services.
The delivery of commercial communications is carried out:
- Based on our previous contractual relationship; or
- Based on your consent, given by checking a box on other forms
You can unsubscribe from these commercial communications at any time through the mechanism indicated in each email or by expressing your willingness to unsubscribe by sending an email to firstname.lastname@example.org.
We will keep all your personal information for as long as our contractual relationship is in force. Once it is terminated, MARFEEL will retain, blocked, said information during the periods established in the legislation to meet any arising liability and to demonstrate compliance with our obligations.
In the event that the delivery of commercial communications is based on your consent, we will keep the information for as long as you are registered on our distribution list for this type of information and, once you agree to unsubscribe, it will remain blocked during the legal periods established to respond to eventual liabilities.
There are no specific transfers of your personal data to fulfill the purpose indicated in this section. However, we may use the services of mail marketing service providers or other advertising and marketing service providers, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how our providers act of services, see point 4. Who do we give your personal information to?> Service Providers).
When we provide certain services to our clients (the “Editors”), they, as Responsible for the processing of your personal data, transmit information to us directly or through our technological platforms through cookies or other tracking devices configured on the Editor’s website.
Please note that Publishers may also use their own cookies or technologies (or those of third parties) to serve ads and monitor their performance. The collection of information through cookies or similar technologies by the Editors or third parties will be governed by their own privacy policies, which, in no case, will be the responsibility of Marfeel.
Information that these Publishers may share with us may include the following:
- Device Information: During the use of the Publisher website, we collect information about the mobile device from which you access the Publisher website. The information we obtain is the device model, operating system and version, the unique identifier of the device and the mobile network.
- Location information: We also obtain your IP address, time zone, and mobile service provider, allowing us to obtain your general location.
- Information about user browsing: we collect information about your use of the Publisher’s website. Specifically, the frequency of use, the sections you visit, the use of specific functions, the time you spend in each section, the scrolling made, etc.
Depending on the services provided to the Publishers, they may submit some additional personal information to us, such as the user ID on the Publisher website.
The specific purposes for the processing of personal data will be defined by the Publisher, who acts as the Controller of the processing of your personal data.
However, in general, our Services to Publishers are focused on optimizing the loading times of their web pages, improvements at the user experience level and at the SEO level, as well as the analysis of advertising performance and improvements in positioning and loading of advertisements within their web pages and the sale of these spaces through programmatic advertising technologies.
Specifically, in the event that the Publisher has our Compass tool configured on its website, you may obtain more information about the standard operation of said tool at the following link: Compass | Marfeel Docs privacy / policy /
Marfeel is a Data Processor in relation to the personal data collected or received from the Publisher (Data Controllers), who provide us with said data through our services. When Marfeel acts as a Data Processor, it processes your personal data on behalf of the Publisher of the website you have visited (the Data Controller / s) on the basis of their instructions. Therefore, it is the responsibility of the PusPublisher to establish an adequate lawful ground for the processing of your data, which must be determined in their own Privacy Policies.
Accordingly, we strongly recommend that you check the Publisher’s website policy for details on the treatment of your personal information.
Your personal data will only be stored in a way that allows your identification for a period not exceeding the necessary for the purposes for which they were collected, in accordance with the instructions given by the Publisher.
At the end of the contractual relationship with the Publisher or when they request it, we will make reasonable efforts to return or irretrievably erase all personal data processed on behalf of our Publisher. However, we may keep the information blocked to comply with the legal retention periods imposed on us or to defend any legal claim.
In general, we will not transfer your data to third parties other than the Publisher, who is responsible for the processing of your data; except if the latter requires us to do so or when required by a public authority, the administration of justice or law enforcement agencies, in compliance with the legal obligations that correspond to us.
However, we may resort to the services of third parties, who will have limited access to the data and will be bound by a duty of confidentiality (for more information on how our service providers act, see point 4. To whom do we transfer your personal information?> Service Providers).
For more information about the processing we carry out through these tracking tools, visit our Cookies Policy.
MARFEEL has a profile on the main social networks, such as Facebook, Twitter, Instagram, Linkedin or YouTube.
When you become a follower of any of our pages on social networks, the processing of data will be governed by the conditions of use, privacy policies and access regulations that belong to the corresponding social network and previously accepted by the user.
MARFEEL, in this sense, will process your data with the purpose of correctly managing your presence on the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of social networks allow.
Keep in mind that we have no influence on the information that the social network collects or how it processes it, so we recommend that you stay informed of the purpose and scope of the information collected through said social networks.
In general, MARFEEL will not transfer your data to third parties. However, in addition to the assignments that we specifically indicate in the section in which we explain the characteristics of the different activities (point 3), we inform you of the communications that we can make, in general, and that affect all the previous treatments and its legitimizing base.
1. MARFEEL group of companies: Personal data may be shared with the rest of the Marfeel group of companies (specifically: MARFEEL COLOMBIA, SAS - Colombia-) for the purposes of management and technical support of the group. Some of the group’s companies are located outside the European Economic Area (EEA), which is why international transfers of your data take place. In this sense, Marfeel has implemented the appropriate procedures and mechanisms to be able to carry out such transfers, as explained in the following section.
2. Providers of essential services to execute the service we offer you, (for example, computer hosting companies or platforms to send commercial communications). Notwithstanding the foregoing, these entities have signed the corresponding confidentiality agreements and will only process your data according to our instructions, not being able to use them for their own purposes or apart from the service they provide us.
3. Public organisms. We may disclose to the competent public authorities the data and any other information that is in our possession or that is accessible through our systems when there is a legal obligation to do so, as well as when it is required, for example, when the purpose is that of prevent or prosecute abuse of services or fraudulent activities through our Website or web page. In these cases, the personal data that you provide us would be kept and made available to the administrative or judicial authorities.
4. In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of its assets or any other type of corporate transaction involving a third party, we may share, disclose or transfer user data to the successor entity (including during the pre-transaction phase).
5. To third parties after aggregation or anonymization: we may disclose or use aggregated or anonymized data (that is, which is not linked to an identified or identifiable natural person) for any purpose.
As indicated in the previous section, some of the Marfeel group companies are located in countries outside the European Economic Area (“EEA”):
- MARFEEL COLOMBIA SAS– Colombia-
In addition, some of our service providers may also be located outside the EEA.
The location of these companies outside the EEA implies the existence of an international transfer of your personal data, which could entail a lower degree of protection than that contained in European regulations. However, at MARFEEL we have applied measures so that said transfers do not give rise to a lower degree of protection of your personal data.
In this sense, all have signed the corresponding standard contractual clauses approved by the European Commission (“SCC”), an agreement signed between both entities by which the non-EU company guarantees that it applies European data protection standards.
Therefore, the use of these providers does not give rise to a lower degree of protection of your personal data than the use of providers located in the European Union. You can check the content of the SCC in the following link:
If you want more information about the international transfers that can be made from Marfeel, you can request it through email@example.com.
You can exercise the rights that the law grants you in relation to the processing of your personal data by contacting our Data Protection Officer through the email firstname.lastname@example.org.
Any request for rights that we receive will be resolved as soon as possible and, in any case, within the maximum period established in the regulations since when we receive it. In some cases, it will be necessary to request a copy of your identity document or other identification document if it is necessary to verify your identity.
The rights that correspond to you as an interested party, are the following:
1. Right to withdraw consent
You can withdraw your consent in relation to all processing based on it, at any time. However, the withdrawal of consent will not affect the lawfulness of the processing based on consent before its withdrawal.
2. Right of access
You have the right to know what data is being processed, if applicable and, if so, to obtain a copy of it, as well as to obtain information related to:
- the origin and recipients of the data;
- the purposes of the processing;
- whether there is an automated decision-making, including profiling;
- the data retention period; and
- the rights provided by the regulations.
3. Right to rectification
You have the right to obtain the rectification of your personal data or to complete them when they are inaccurate.
4. Right to erasure
You have the right to request the erasure of your personal data if it is no longer necessary in relation to the purposes for which they were collected or, where appropriate, if we are no longer authorized to process it.
5. Right to data portability
You have the right to request the portability of the data in the case of the processing of your data that is based on consent or on the execution of a contract, as long as the processing has been carried out by automated means. In case of exercise of this right, you will receive your personal data in a structured, commonly used and machine readable format. However, you can also request, when possible, that your data be transmitted directly to another company
6. Right to restriction of processing of your personal data
You have the right to restrict the processing of your data in the following cases:
- When you have requested the rectification of your personal data during the period in which we verify their accuracy.
- When you consider that we are not authorized to process your data. In that case, you can ask us to limit its use instead of requesting its deletion.
- When you consider that it is no longer necessary for us to continue processing your data and you want us to keep it for the sole purposes of exercising or defending legal claims.
- In cases where there is a processing based on our legitimate interest and you have exercised your right to object, you can ask us to limit the use of your data during the period in which the verification, whether our legitimate interest overrides yours, is taking place.
7. Right to object
You have the right to object at any time to processing of your personal data based which is based on our legitimate interest, including profiling.
Cancellation of commercial communications: Remember that at any time you can oppose the receipt of this type of communications by sending us an email to email@example.com. You can also exclude yourself from this service by following the instructions indicated at the bottom of the body of each of the electronic communications that we send you.
8. Right to lodge a complaint with a Supervisory Authority
Remember that, at any time, and in case you consider that we have infringed your rights, you can lodge a complaint within the corresponding Supervisory Authority. In the case of Spain, it is Spanish Data Data Protection Agency ( www.aepd.es).
The security of your personal data is a priority for us. For this reason, MARFEEL has implemented all the necessary security measures to guarantee an effective use and processing of the personal data provided by the users, safeguarding their intimacy, privacy, confidentiality and integrity of the same and makes use of the technical means necessary to avoid the alteration, loss, unauthorized access or treatment of your data, according to the state of technology at all times.
Consequently, we comply with the recommended security standards to protect them. However, it is impossible to fully guarantee your security due to the very nature of the Internet and because there may be malicious actions by third parties beyond our control.
We are committed to acting swiftly and diligently in the event that data security is compromised or compromised, and to informing you of this where relevant.
Below, we put at your disposal the laws and regulations that assist you, protect and establish your rights, which have inspired this policy:
General Data Protection Regulation EU 216/679
Organic Law 3/2018, of December 5, on Protection of Personal Data and guarantee of digital rights.
Law 34/2002, of July 11, on services of the information society and electronic commerce
According to CCPA provisions, MARFEEL is not considered a Business.
Over the past twelve (12) months, your Personal Data has not been sold to third parties as part of the use of Marfeel’s website, as the term “sell” is defined in the CCPA.
Opting out of the Sale of Your Personal Information by the Publishers. Regarding the personal information we receive from our clients (Publishers) in the framework of our services to Publishers, you may exercise your right to opt out of the sale of your personal information directly to the Publisher (see the “Do not Sell My Personal Information” link on the Publisher’s websites you are visiting or visited). If we receive an opt-out request from a Publisher relating to you or any other individual, we will cease sharing your/their information with the media buyers for advertisements that are displayed to you/them when you/they visit properties of other Publishers.
As a California consumer, you have the right to request access to the personal information that has been collected about you in the last 12 months.
You may also request additional details about our privacy practices, including information about:
· the sources of personal information,
· the commercial or business purpose for collecting or selling your personal information,
· the categories of third parties with whom we share your personal information and/or those with whom we have shared your information in the previous 12 months,
· the categories of personal information that we have disclosed and sold about you in the previous 12 months
This request is limited to two times in a 12-month period.
If you are a California consumer, you also have the right to request the deletion of your personal information in certain circumstances, to opt out of sales of personal information (where applicable) and to receive the same service and price, and to be free from discrimination, even if you exercise any of your rights under the CCPA. Take into account that we may deny your deletion request when certain exceptions are met, for instance, when your data need to be retained to provide you with a service or to complete a requested transaction.
When Marfeel act as Data Processor, your request should be addressed to the Publisher whose website you visited. However, you may also address your request to Marfeel, as service provider, sending an e-mail to firstname.lastname@example.org. We will make every effort to forward your request to the appropriate Publisher and process and manage it according to applicable laws.
Please note that your request must include sufficient information to allow us to reasonably verify that you are the person about whom we have collected personal information.
Marfeel will not discriminate against a subject for the exercise of his or her rights under the CCPA.
In any case, if your personal data are shared with third parties, the recipients must use them in accordance with the purposes for which they were collected, or, if applicable, for which you previously authorized.
As data subject under the LGPD, you, at any time and by means of request, has the right to obtain the following:
· confirmation of the existence of the processing of your personal data;
· access to your personal data, which will be provided in a readable format in printed form or by electronic means;
· anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD;
· portability of the data to another service provider or product provider, by the means of an express request, except when the data have already been anonymized;
· deletion of your personal data when its collection was based on your consent, except when the storage is needed for the purposes authorized by law (such as compliance with a legal or regulatory obligation or use of anonymized data)
· information about public and private entities with which the data have been shared;
· information about the possibility of denying consent and the consequences of such denial;
· revocation of your consent;
· review of decisions made solely based on automated processing of personal data affecting your interests, or information on the criteria and procedures used for an automated decision, subject to commercial and industrial secrecy.
The regular exercise of your rights will not be used to your detriment.
Moreover, You have the right to petition, regarding your personal data, against the Data Controller before the national authority, before consumer defense entities or in court, individually or collectively, as provided in pertinent legislation
When Marfeel acts as Data Processor, your request should be addressed to the Publisher whose website you visited. However, you may also address your request to Marfeel, as data processor, sending an e-mail to email@example.com. We will make every effort to forward your request to the appropriate Publisher and process and manage it in accordance with applicable laws.