DATA PROTECTION POLICY OF TWIN FREE SMS - TWINSMS

Data Protection

According to the RGPD and current legislation, we inform you that your personal data will be treated in accordance with the principles of transparency, purpose limitation, data minimization, accuracy, integrity and confidentiality by TWIN FREE SMS - TWINSMS, property of MercadoPC Iberia SL, who will guarantee as Responsible for Data Processing and in compliance with current legislation, the exercise of all available rights. In the different forms we will only ask you for those data necessary for the provision of the services of the app and/or the web portal, and they will only be used for the purposes stated. TWIN FREE SMS - TWINSMS ensures the confidentiality of the data provided and guarantees that, in no case, will be transferred for any other use except those indicated, without the prior and express consent of the user.

During registration, the user declares that he/she is of legal age, therefore we will not deal with information about minors, or any sensitive information, such as those related to health, sexual or union orientation, religion or race. If we detect any collection of personal data from minors or sensitive data, we will delete such data, unless we are required by law to retain such data.

The user undertakes to provide TWIN FREE SMS - TWINSMS with truthful, complete, accurate and up-to-date data at all times, and undertakes to keep them duly updated.

The personal data that the user must provide are essential to enjoy the services offered by the app and / or the web portal, so if the user does not want to provide them, he may not enjoy the services available. By providing the data and registering, the user undertakes to provide authentic and updated personal data. Providing false or incorrect information is contrary to the conditions of use of the app and/or web portal, and/or the services offered by TWIN FREE SMS - TWINSMS.

Responsible:

TWIN FREE SMS - TWINSMS, property of MercadoPC Iberia SL located in C/ San Francisco, 3 - 1º de Villena (03400), Alicante, Spain, inscribed in the Mercantile Registry of Alicante, Volume 3185, Book 0, Folio 46, Page A-106545, Inscription 2ª, CIF B54237151 usuarios@twinsms.com

The user may also contact the Data Protection Delegate at dpro@mercadopc.com

Purpose:

The data provided by the user to TWIN FREE SMS - TWINSMS will be treated according to the following purposes:

1.-Purposes that require express consent:

We treat the information provided by the user for the purpose of maintaining your free account of the app and / or the web portal, with such information we can manage from the registration process to the management of requests, incidents or queries of the user, either through contact forms, email or instant messaging.

With the required data we manage and process the user's account, which allows the user to enjoy the free services of sending and receiving instant messages and sms, the introduction by the user of information on his wall and its subsequent sending to their followers, and the reception of promotional messages (newsletters in the form of emails and / or instant messages) proposing the latest news, offers, etc. , regarding the products and/or services shown in the app and/or the web portal www.twinsms.com, or the latest news or most outstanding offers from the company owning the app and the web, MercadoPC Iberia SL.

When the user gives permission to other third parties, such as our collaborators or suppliers to share their information with us. Or when you decide to share your social network data.

To improve our services, maintain the security of our networks and prevent fraud, TWIN FREE SMS - TWINSMS complying with current legislation, also requests the user's permission to obtain anonymous statistical data of their browsing the website and / or use of the app. Web visit data: are the data of the public IP address, date and time of connection, the web pages consulted or the applications used by the client, the IP of the web that the client consults, domain name (URL). This express consent will become legitimised by compliance with a legal obligation when the user uses any of the available communications services. The user may at any time consult the information on cookies that TWIN FREE SMS - TWINSMS provides, as well as their rights, always exposed in the cookie policy section. The partial or total diminution of the functionalities of the app and/or the web site by the blocking or the elimination of cookies carried out by the user will not be the responsibility of TWIN FREE SMS - TWINSMS.

To help and speed up the delivery of addresses, your terminal's positioning data is used. The geolocation data collected are never used to evaluate users, they are only collected to make it easier for the user to send locations, in the same way as if the user entered the address manually. At any time the user can block this collection by turning off or disconnecting the gps in his terminal. If gps is not active, the user will have to enter the addresses manually.

The free services are offered to the client thanks to commercial sponsorship, therefore we request the express consent of the user for the receipt of commercial information, and we will always provide, with respect to the receipt of such commercial information, a simple mechanism for unsubscribing. The renunciation to the reception of commercial information can suppose the cancellation as user of the app and/or of the web www.twinsms.com and the elimination of all the information inserted by this user, because without the commercial sponsorship these services cannot be offered. TWIN FREE SMS - TWINSMS certifies that at no time the data of registered users who use its services will be transferred to advertisers.

We remind the user that we are always evaluating our commercial interests to ensure that they never collide with or prejudice their rights.

2.-Purposes for compliance with a legal obligation:

And we process user data to fulfill a legal obligation, for example to fulfill our accounting and tax obligations, or to retain traffic data for the purpose of complying with current legislation on data retention, among others. Traffic data: data associated with the detail of sending messages, user identification of origin and destination, type of message (national, international, etc ...), date and time.

Data retention periods:

We will always store the information collected from the user during the time set by law, and in those cases where there is no legal period required, will be stored for the minimum period necessary to undertake those tasks or services for which they were collected.

The user's registration and management data, and in general those processed during the enjoyment of the services offered by TWIN FREE SMS - TWINSMS, will be stored for an additional maximum period of 6 years from the last activity and/or access of the user in the app and/or the web, in order to comply with our accounting and tax obligations and in compliance with the application of the Civil Code and tax regulations.

Data related to electronic communications and communications networks will be stored for a period of 12 months, in compliance with current legislation, including Law 25/2007 of 18 October.

We will retain user data for as long as the purpose for which it was collected is maintained. When they are no longer necessary for this purpose, those data that are necessary during the legally established periods to attend any question related to their treatment will be kept blocked, up to a maximum of 6 years, in order to be able to comply with current legislation. Once the legal deadlines have elapsed, the personal data will be deleted by adopting the appropriate security measures that guarantee their total destruction at all times.

Legitimation:

The legal basis for the processing of personal data is the express consent required of the user for each of the purposes of processing, both for registration and for the receipt of advertising and / or any enjoyment of the functions available in the app and / or the web.

Although express consent is our main legitimate basis for the processing of data, and therefore is always requested from the user after having provided sufficient information on the purpose of data processing, by legal imperative, this express consent is replaced by a legitimate basis for the provision of services, when users use the available services, all free, including communications, because in all these cases must comply with the obligations imposed by accounting legislation, tax and telecommunications.

Only ask the user the essential data to offer the services available in the app and / or the web portal, therefore if the user refuses to provide them, unfortunately he will not be able to enjoy the services available.

Recipients:

Information we share:

There is no provision for any transfer or transfer of data to third parties except legal obligation, therefore the user's data will not be transferred except to agencies of the Public Administration such as, but not limited to, tax authorities, judicial authorities, authorities competent in telecommunications, judicial police, and any other body that depending on the regulations and legislation in force may require the transfer of information.

TWIN FREE SMS - TWINSMS will only allow access to the user's data by third parties when their intervention is necessary for the provision of a service, and always complying with the measures required by current legislation.

TWIN FREE SMS - TWINSMS has contracted for the management and development of some of the services offered to users to trusted providers, who as processors may have access to user data for the sole purpose of fulfilling the task for which they have been contracted, and therefore will be contractually bound to comply with their legal obligations as processors, to maintain confidentiality and secrecy of information.

TWIN FREE SMS - TWINSMS confirms to the user that under no circumstances will their personal data be transferred to third parties without obtaining their prior consent, unless the transfer of their data was necessary to ensure the maintenance of the services available in the app and / or web portal and / or to comply with a legal obligation, as well as in the cases provided for by existing legislation.

No international transfer or transfer of data is foreseen, and in the event that there are any, the user will be informed in advance to request their express consent.

Due to the Internet infrastructure it is possible that TWIN FREE SMS - TWINSMS makes use of external service providers from countries outside the European Union (EU) in order to be able to offer its services, and it should be borne in mind that some countries outside the EU do not always have an equivalent level of privacy protection, therefore TWIN FREE SMS - TWINSMS will take specific measures to protect at all times the user's personal data in accordance with the legislation in force, and will update this document including such providers, if any, to keep the user informed in advance.

When the user connects our services with external platforms such as social networks, he requests this transfer on his own initiative, and therefore expressly and unequivocally accepts his consent for the processing of his data and for the international transfer of the same to the service providers who own the social networks, as most of them are located outside the EU. In the social networks which can be consulted below, the user can expand this information.

Due to the importance of data processing in the messaging service, TWIN FREE SMS - TWINSMS wants to reflect that when a user sends an international message using our services, you give your express consent for your data (your telephone number as sender, your message and the recipient's number) to be communicated to other communications operators, including the recipient operator, and may pass such data through several operators in the case of international communications. Therefore TWIN FREE SMS - TWINSMS only certifies that it will always send its messages through certified communication operators, but the routes, operators and countries for which they must pass such data can never be controlled by TWIN FREE SMS - TWINSMS due to the nature of the communication systems, therefore the user exempts from any responsibility to TWIN FREE SMS - TWINSMS on the processing of data relating to the message made by operators, responsible for transferring the message to the number of the recipient. Therefore, the user sending the international message explicitly gives his consent for access to his data by operators from other countries, after having been informed of the possible risks for him of sharing such information for the delivery of his message, due to the absence of a decision on adequacy and adequate guarantees on the processing of the data involved, which may be offered by the operators through whom the message will transit to its destination.

Whenever TWIN FREE SMS - TWINSMS sends information to a country that is not part of the EU, it will ensure that the user's information is protected, and in the event of access to data for the provision of a service, there will always be a contract for the data processors to comply with current regulations, except in international communications, TWIN FREE SMS - TWINSMS only certifies that it will use the channels approved by regulators to transmit the messages, in accordance with current telecommunications regulations.

The services available within the mobile platforms (Android, Apple...), such as, for example, the notification service, among others, involve data processing and a possible transfer of international data for the provision of the notification service, which is carried out within the framework of the mobile platforms themselves, whose owners impose rules of operation, therefore the obligations on data transfer that may assume TWIN FREE SMS - TWINSMS are limited to those aspects that the platform allows, so the user must always consult in such platforms the treatment they offer, prior to registration in them. TWIN FREE SMS - TWINSMS will help and advise the user at all times to the extent of their possibilities.

Android - Google platform: https://policies.google.com

Apple platform: https://www.apple.com/legal/privacy/es/

Rights:

The user may at any time exercise his/her right of access, right of rectification, right of suppression, right of limitation, right of portability and right of opposition, by sending an e-mail to usuarios@twinsms.com or by letter to MercadoPC Iberia SL, C/ San Francisco, 3 - 1º de Villena (03400), Alicante, Spain, attaching a document proving his/her identity.

The user can withdraw the consent given at any time by simply sending a request to the contact details provided above, attaching document proving their identity.

In the event of any doubt or complaint, the user may contact the Data Protection Delegate at dpro@mercadopc.com

The user may file a complaint with the Data Protection Agency (www.agpd.es) when he or she has not obtained satisfaction in the exercise of his or her rights.

Social Networks:

TWIN FREE SMS - TWINSMS have open profiles in the main social networks (Facebook, Twitter, Instagram and Google Plus ...), with the sole purpose of disseminating relevant information about the company, informing about the available ways of contact, and resolving small doubts of users, therefore will not extract data from social networks to be treated. By owning such profiles on social networks, TWIN FREE SMS - TWINSMS recognizes itself as responsible for the processing of data of its followers, fans, subscribers, commentators and any type of user who interacts with your profile. The treatment will be, at most, that which the social network allows to corporate profiles.

As the processing of personal data is carried out within the framework of social networks, whose owners impose operating rules, the obligations that TWIN FREE SMS - TWINSMS can assume are limited to those aspects that the platform allows, therefore when for the exercise of the rights of the user TWIN FREE SMS - TWINSMS cannot resolve them due to the limitations that the platform imposes, the user must proceed with the modification of his profile on the social network. It should be noted that TWIN FREE SMS - TWINSMS will help and advise the user to the extent of their possibilities, whenever required to exercise their rights.

In no case TWIN FREE SMS - TWINSMS will proceed with the extraction of data or information from social networks, create profiles or collect data without the express consent of those concerned.

By accessing our social network profiles or by using the plugins of the networks themselves while browsing the web or using the app, the user expressly and unequivocally accepts their consent for the processing of their data, and for the international transfer of the same to the service providers who own the social networks.

https://es-es.facebook.com/privacy/explanation

https://twitter.com/es/privacy

https://policies.google.com

https://www.instagram.com/legal/privacy/

Sometimes users are offered the possibility of registration or access to TWIN FREE SMS - TWINSMS using their profile on social networks. In order to use this option, the user must give their consent for TWIN FREE SMS - TWINSMS to collect the same data from their profile on the social network as they would request by filling out the registration or access form. This service is only a help that we offer the user to avoid the process of filling in and completing the form, and TWIN FREE SMS - TWINSMS certifies that it will not collect any data from their profile other than those requested on the forms enabled for registration or access. If the user does not give his/her consent for this function, he/she will have to fill in the enabled forms manually in order to be able to register or access.

Before authorizing the connection of TWIN FREE SMS - TWINSMS to the user's account on an external platform or social network, the user should review and ensure the privacy notices and policies of that platform or external account, so that it has knowledge about the data that may share the external platform or social network with other parties.

Social network plugins and applications are always managed by the social network itself and are subject to their own terms of use and privacy and cookie policies. We recommend that the user check the terms of use and privacy policies before using them.

A priority mission: Data Protection:

TWIN FREE SMS - TWINSMS constantly adopts, reviews, updates and improves all security measures to provide the best protection of user data against loss, unauthorized access, misuse, disclosure, alteration and/or destruction. There are different levels of protection assets ranging from the use of firewalls and data encryption to physical access controls to servers. Therefore, we only ask the user to maintain adequate levels of security, not to use very simple or common passwords (type 1234 and similar), not to share them or publish them in any type of media, and remember to keep your data updated at all times. TWIN FREE SMS - TWINSMS is not responsible for the protection of data transferred after the user's request to share them with external platforms or social networks.

As indicated in the terms of use, TWIN FREE SMS - TWINSMS is not responsible for the content, privacy policy and / or availability of apps and / or websites of third parties that the user can access through external links available on TWIN FREE SMS - TWINSMS. We recommend the user to read and check the privacy and cookie policies of these external companies, before providing any personal information on their websites and / or apps.

The user should remember that some communications over the Internet (e.g. emails) are not secure unless they have been encrypted. In addition, these communications may pass through an indeterminate number of countries before being delivered due to the Internet's own configuration.

We will never request personal information from users through unofficial means or channels.

If you have any questions, please contact us as soon as possible before providing your information.