This policy (hereinafter referred to as "Privacy Policy" or "Policy") is effective as of December 1, 2024 ("Effective Date"). The owner of the website voupy.com (hereinafter referred to as the "Website") is CARDOCK HOSTING LIMITED (hereinafter referred to as "the Company" or "we"), a company with registered office at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ, Register number: 11086647. The Company operates in the field of permission e-mail marketing (advertising campaigns with the consent of the recipient). Mainly, he is dedicated to direct marketing, affiliate marketing, online advertising and telemarketing. You can contact us, with any questions about this Privacy Policy, at the address dpd@voupy.com and/or at CARDOCK HOSTING LIMITED, 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ. The content of this Privacy Policy is as follows:
1. SCOPE OF APPLICATION AND LIABILITY
2. COMPANY SERVICES
3. PERSONAL DATA COLLECTED BY THE COMPANY
4. USE OF DATA COLLECTED BY THE COMPANY
5. PURPOSE OF DATA PROCESSING AND LEGITIMATE CAUSE
6. TYPES OF DATA PROCESSING
7. ACCESS TO YOUR PERSONAL DATA AND INTERNATIONAL DATA TRANSFERS
8. AGE TO REGISTER ON THE WEBSITE AND ACCOUNT SECURITY
9. RIGHTS OF DATA SUBJECTS IN RELATION TO THEIR DATA
10. COMMERCIAL COMMUNICATIONS
11. SECURITY AND CONFIDENTIALITY OF DATA
12. DECLARATION OF GOOD PRACTICE
13. VALIDITY OF THE PRIVACY POLICY
14. DESIGNATION OF DPO. CONTACT US
1. – SCOPE OF APPLICATION AND LIABILITY
Cardock Hosting Limited (hereinafter referred to as "the Company") is the controller of your personal data (e.g. information that identifies an individual, such as your full name or email address) collected through our services, in accordance with this Privacy Policy. This Privacy Policy, as well as our Cookie Policy, applies to all users, both those who use our services without having registered or subscribed to any of them, and those who have registered or subscribed to one of our services.
For clarification, this Privacy Policy does not apply to data collected by third parties through their websites, even if any such websites contain links to the Company's Website. Cardock Hosting Limited is not responsible for any content within the third-party privacy policy, and makes no warranties, express or implied, in relation to the accuracy, legality, accuracy, or validity of any third-party website.
2. – COMPANY SERVICES
The Website offers you the possibility of receiving newsletters and coupons related to the products and services of CARDOCK HOSTING LIMITED and/or third parties. The newsletters and coupons mentioned above will be based on the interests you have indicated to us, in accordance with the criteria of the website and your profile.
To use the services of CARDOCK HOSTING LIMITED, you must register on the Website through the registration form provided, and freely and expressly consent to the processing of your email to receive newsletters, coupons and other commercial information, in accordance with this Privacy Policy and our Cookies Policy.
In addition, you can at any time manage your preferences for receiving commercial communications, either to stop receiving newsletters or coupons, by following the instructions provided in each communication.
CARDOCK HOSTING LIMITED will only collect and process the email address you provide when registering. Your data will be treated confidentially and will not be shared with third parties for purposes other than those set out in this Privacy Policy.
3. – PERSONAL DATA COLLECTED BY THE COMPANY
The Company collects information to provide services to you, either directly, through the personal data provided by the user, or indirectly through the use of the Website and the services it provides (device-related information and registration data). In particular, the Company collects the following data from and about you:
to. Data provided by the user for the purpose of registering for a service of the Company. Subscription forms request personal data through mandatory fields that the user must complete, such as their email address, in order to be able to manage our subscriptions and send them newsletters, coupons or offers. Registration is carried out through a form provided on the Website, and the user must consent to the processing of their data in order to receive such communications. To verify your email, you will receive a message from the Company with the subject "Successfully registered in our newsletter of exclusive offers" or similar. The requested data is used only to send you newsletters or coupons for products and services of CARDOCK HOSTING LIMITED and/or third parties. At any time, you may revoke your consent or request to be removed from the list of subscribers, following the instructions provided in each communication.
b. Social Media Information. If you access or register for a Company service through a social network or connect a Company service to a social network, the data we obtain may include your user identity and/or the username associated with such social network, any information you allow the social network to share with us (such as your profile picture or email address), and any other personal data that you have made public through said social network. Social networks may collect additional personal information, such as the web pages you have visited and your IP address, and may place cookies on your device. The Company is not responsible for the security or privacy of any information collected by these third parties. You should read and understand the policies applicable to third-party services before consenting to such services.
c. Information submitted to the Company via a contact form. There is a contact form on the Website for inquiries, suggestions and/or professional matters. If you contact us through this online form, we will use your email address to respond to you and send you the information requested by you, if applicable.
d. Activity data. When you access and interact with our Services, we may obtain information about your activity on the Website. For example, our servers may store information about your device and browser, such as your IP address, browser type, and other information about the software or hardware used. We may also install cookies and other tracking technologies (such as browser cookies and beacons) to obtain and store information about your use of our services, such as the pages you visit, the content you view, and the advertisements shown to you. For more information, please see our Cookie Policy.
and. Information from other sources. We may supplement the information we collect with information from other sources, such as publicly accessible information on social media services and commercially available sources.
Data retention period
Personal data will be kept for two (2) years from the date on which they were provided to the Company, or until the user requests to be removed from the mailing list or subscription. The Company may retain the data longer if there is a legitimate interest overriding the user's interests or to pursue legal claims. After the retention period has elapsed, the data will be deleted, anonymised or aggregated.
User Rights Under UK Data Protection LegislationIn accordance with current legislation in the United Kingdom (UK GDPR), users have the following rights with respect to their personal data:
If you wish to exercise any of these rights, or if you have any questions about how we handle your personal data, you may contact us at the addresses indicated in this Privacy Policy.
4.- USE OF THE DATA COLLECTED BY THE COMPANY
We use the personal data we collect from you to:
a) To provide you with the Company's services: To manage, maintain and offer the requested services, as well as to provide you with access to our platforms and content.
b) Measure, analyse and improve our services: Evaluate the performance of our services, carry out research to improve their characteristics and optimise their operation.
c) To provide you with our customer service: To respond to your queries, manage incidents and provide you with the necessary help to solve problems related to our services.
d) Protect the rights of the Company and others: Ensure the safety, security and proper administration of the services, protect the rights of the Company, Group entities, employees, agents, contractors, licensors, suppliers, users of our services or third parties, and defend against legal claims.
e) Manage your browsing and alert settings: Offer you the possibility to personalise your browsing experience, as well as manage and configure alerts or notifications on our services.
f) Allow you to participate in promotions, contests and/or sweepstakes: Manage your participation in promotions, contests, sweepstakes and other commercial activities organized by the Company.
g) Comply with applicable laws and legal proceedings: Comply with UK legal regulations, respond to requests from authorities or government, and cooperate with public bodies if necessary.
h) Executing corporate operations: In the event that the Company participates in corporate operations (e.g., merger, sale, joint venture, assignment, transfer or other disposition of all or part of the business, assets or shares), your personal data may be communicated or transferred to the parties involved in such transactions.
i) Log in via a social network: Allow you to access our services using the credentials of your social network linked to our system.
j) Send you commercial communications: With your prior consent, we may send you by email, SMS, telephone, social networks or other means of communication offers, promotions and other commercial communications about products and services of the Company, its Group entities, and/or third parties operating in sectors that may be of interest to you, according to your profile and the cookie settings of your browser. You can read our Cookie Policy for more details.
k) Sharing data with third parties with your consent: With your explicit consent, we may share your data with third parties to carry out commercial and telemarketing practices in sectors in which you may be interested. This processing is optional and will only be carried out if you expressly accept that your data will be transferred to these entities.
Sectors of Interest
Sectors to which we can target communications and business practices include, but are not limited to:
Direct Marketing and Profiling
The Company may conduct direct marketing through e-mail marketing, telemarketing, and other forms of contact. In addition, we may carry out segmentation and profiling processes, combining your data with other sources of information to provide you with more relevant advertising. These profiles can be based on various aspects such as their behavior, interests, location, or trustworthiness. We use these processes to improve the effectiveness of our advertising campaigns and to ensure that advertisements are tailored to your interests.
Rights over your Personal Data
At any time, you have the right to access, rectify, erase, limit, object to the processing of your data, as well as to exercise other rights set out in the United Kingdom law (UK GDPR). To exercise these rights, you can contact us by following the procedures indicated in our Privacy Policy.
ConsentIn some cases, the processing of your personal data will be based on your explicit consent (e.g. to receive marketing communications). In these cases, you may withdraw your consent at any time without affecting the lawfulness of the processing carried out prior to its withdrawal.
5.- PURPOSE OF DATA PROCESSING AND LEGITIMATE CAUSE
Your personal data is collected and processed by the Company for the following purposes:
• The data processing described in letters a) to f) of Section 4 of this Privacy Policy is necessary for the provision of the Company's services. The personal data requested is mandatory. Refusal to supply them will make it impossible to carry out the provision of the contracted services.
• The data processing described in Section 4(g) of this Privacy Policy is mandatory and requested in accordance with the requirements of applicable laws, including data protection regulations.
• Section 4(h) of this Privacy Policy is made based on the legitimate interest of the Company and its counterparties to carry out the aforementioned economic activities. This processing is not mandatory and you have the right to object to it at any time, by following the instructions specified in Section 13 of this Privacy Policy.
• Section 4(i) of this Privacy Policy is discretionary. However, without your explicit consent, it will be impossible to connect your social media account with the Company's services. If applicable, you'll need to use another login mechanism if you don't want to link a social media account.
• Letters j) and k) of Section 4 of this Privacy Policy are also discretionary. Without your explicit consent, it will not be possible for the Company or third parties to provide you with generic commercial communications of services and/or products of the Company or third parties, or to make communications based on your interests and needs. Sometimes, we will segment advertising campaigns through profiling. This profiling is only carried out with the data that you have provided and consented to directly to the Company through your registration form (e.g. your name, telephone number and email address). Profiling does not involve tracking your activity across multiple websites, apps, or services.
• With your prior consent, the Company may transmit or transfer your data to third parties for the purpose of carrying out commercial and telemarketing practices in sectors of activity in which you may be interested.
Revocation of Consent
If you wish to revoke your consent to the processing of your personal data or exercise your right to object to receiving marketing communications, you may contact us using the contact details specified in Section 13 of this Privacy Policy. For the purpose referred to in Section 4(i), you may unsubscribe from marketing communications by clicking on the unsubscribe link in any marketing communication.
By ticking the corresponding box, you are giving your free and express consent to receive advertising, the transfer of your data to third parties, as well as to accept our Terms and Conditions, Privacy Policy and Cookies Policy.
Direct Marketing and Service Providers
The Company, in order to carry out direct marketing actions, will enter into agreements with third parties that are suitable service providers. These providers will provide their services in the sectors indicated in Section 4 of this Privacy Policy and will process personal data in accordance with the Company's precise instructions. Such providers shall comply with applicable data protection, information security and other relevant regulations. Their task will be to support the Company in the management of advertising campaigns and in the conversion of such campaigns into product purchases or subscriptions to services. To this end, the personal data will be provided to these third parties, who will carry out the direct marketing actions. This data processing is based on the existing contractual relationship between the Company and you, after registration and consent for the processing of your data.
6.- TYPES OF DATA PROCESSING
Your personal data are processed by automated and non-automated means, and are protected by appropriate security measures, taking into account the state of the art, the costs of implementation, the nature, scope, context and purposes of the processing.
The Company implements appropriate administrative, technical, personnel, and physical measures to protect the personal data in its possession from loss, theft, and unauthorized use, disclosure, or modification. Our information security policies and procedures align closely with international standards, which are widely accepted, reviewed and regularly updated to suit our business needs, technological advancements and applicable regulatory requirements.
The Company has designed a business continuity plan to deal with adverse and unexpected events, in order to ensure the continuity of our services for our clients and protect our assets and personnel.
We appropriately restrict access to personal information and implement necessary measures and controls, including physical and supervisory controls, to store and transfer the data securely. In addition, we require our employees and contractors to receive ongoing training in the area of information security.
However, you should be aware that, despite our security measures, it is not possible to guarantee the absolute security of personal data transmitted over the Internet. Online security measures are not foolproof, and therefore there is always a residual risk.
7.- ACCESS TO YOUR PERSONAL DATA AND INTERNATIONAL DATA TRANSFERS
The Company may share your personal data with the following categories of recipients, in compliance with and within the limits established by applicable law:
• Third-party service providers, to whom the Company entrusts data processing activities, duly designated as processors when required by applicable laws. This includes cloud service providers, other Group entities, technology service providers, experts, consultants and lawyers, among others. You can request a list of our data processors by contacting us.
• Companies resulting from corporate transactions, such as mergers, spin-offs or other corporate transformations.
• Collaborating companies. With your prior consent, the Company may share your personal data with collaborating companies in the sectors you have indicated, in accordance with Sections 2 and 4 of this Privacy Policy, mainly for the purpose of sending you commercial communications.
• Competent authorities, in compliance with applicable laws. Your personal data may be transferred to countries within and outside the European Economic Area ("EEA"). Some countries outside the EEA have been recognised by the European Commission as offering an adequate level of data protection, in line with EEA standards. You can consult the full list of these countries at this link from the European Commission. For transfers of data from the EEA to countries that are not considered appropriate by the European Commission, we have put in place sufficient measures and appropriate safeguards, such as the Standard Contractual Clauses adopted by the European Commission, as set out in Articles 45 and 46 of the EU General Data Protection Regulation 679/2016 ("GDPR").
You have the right to request additional information about international transfers of your personal data by contacting the Company at the addresses indicated in Section 13 of this Privacy Policy.
8.- AGE TO REGISTER ON THE WEBSITE AND ACCOUNT SECURITY
Registration on the Website is limited to users over the age of eighteen (18). An authentication mechanism prevents the registration of (a) those who do not enter a valid birth year, which must prove that you are of legal age, and (b) those who do not expressly accept your age of majority. By registering on the Website, you warrant that you are of legal age. All registration information you submit to create an account must be true, accurate, complete, and current. You acknowledge that you will be liable for any damages, direct or indirect, that may arise from any breach of this obligation. If the data provided belongs to a third party, you warrant that you have informed such third party of the above-mentioned aspects herein and have obtained their consent to provide the data to the Company for the purposes specified in this Privacy Policy.
You are responsible for maintaining the confidentiality of your password and are responsible for the use of your account. Therefore, it is critical that you do not share your password with anyone. You agree not to use the account, username, email address, or password of another member or subscriber at any time. In addition, you agree to notify the Company immediately if you suspect that your account or password has been used without authorization or has been subject to unauthorized access.
9.- RIGHTS OF THE INTERESTED PARTIES IN RELATION TO THEIR DATA
Through this Privacy Policy, we inform you that you have the right to exercise your rights, free of charge and when you deem it appropriate, as established in current regulations, in relation to:
• Access to your own personal data;• Rectification of inaccurate or incomplete data;• Deletion of your personal data;• Opposition to the processing of your data;• Obtain the restriction of the processing of your data when any of the conditions provided for in the data protection regulations are met;• Portability of your data.
To exercise the rights mentioned above, you may send your request by email to dpd@voupy.com or by written communication addressed to CARDOCK HOSTING LIMITED, Register number: 11086647 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.
If you believe that the Company has infringed, or may have infringed, your rights under applicable data protection regulations, you may lodge a complaint with the relevant Supervisory Authority. In the United Kingdom, the Supervisory Authority is the Information Commissioner's Office (ICO), whose website is www.ico.org.uk. You can contact the ICO by mail at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom.
10.- COMMERCIAL COMMUNICATIONS
The content of communications sent by electronic means of communication complies with the regulations established in the General Data Protection Regulation (GDPR), the United Kingdom Data Protection Act 2018 (UK GDPR), and Law 34/2002, of 11 July, on information society services and electronic commerce ("LSSI"). In addition, these electronic communications comply with electronic communications legislation in the United Kingdom, specifically the Privacy and Electronic Communications Regulations (PECR).
These emails include a link to unsubscribe from our marketing communications, as well as the instructions you should follow in case you are interested in exercising your rights in terms of data protection, in accordance with Section 9 of this Privacy Policy.
11.- INFORMATION SECURITY
For queries related to the products or services of the Third Party Providers once contracted, Users should contact the Third Party Provider of said service or product. On the other hand, any complaint and claim in relation to Arkeero's own services must be sent, in any case, to the Company through the contact details provided above.
12.- DECLARATION OF GOOD PRACTICES
The Company complies with current legislation, in particular with the provisions of the General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 (UK GDPR), the Privacy and Electronic Communications Regulations (PECR), Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), and the Codes of Good Practice in Data Protection.
The Company does not send commercial communications electronically that have not been previously requested or authorized by the User in accordance with current legislation. In addition, the Company will terminate agreements with advertising companies or members of the affiliate network that engage in practices contrary to current legislation.
13.- VALIDITY OF THE PRIVACY POLICY
The Company may modify or update this Privacy Policy for any reason, (including, but not limited to, changes in applicable laws and interpretations, decisions, opinions, and instructions related to such applicable law. Please refer to the Effective Date at the top of this Privacy Policy to check when it was last revised. Any change to the Privacy Policy will be notified, sufficiently in advance, by posting the updated Privacy Policy on the Website. Material changes to this Privacy Policy, which alter the nature of the processing or extend our rights to use your personal data collected by us, will be notified in advance and we will give you a choice regarding our future use of such personal data, in accordance with applicable law.
14.- APPOINTMENT OF DPO. CONTACT US
The company has appointed a data protection officer (DPO). If you have any questions regarding this Privacy Policy, please contact us at the following addresses:
• Email address: dpd@voupy.com
• Dirección postal: CARDOCK HOSTING LIMITED. Register number: 11086647, 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ