Política de Privacidad

Luzia; Madrid; Presencial; EUR 50.000 - 70.000; Jornada completa

Descripción del empleo

LUZIA is committed to respecting the privacy of users and the protection and security of your personal data. Therefore, we inform you about the way in which we collect, treat and protect personal data that are provided through our online platforms.

As a User you should carefully read this privacy policy, which has been written in a clear and simple way, to facilitate your understanding, and determine freely and voluntarily if you wish to provide your personal data to LUZIA.

You also guarantee that the data you share with us are true, accurate, complete and updated, being responsible for any loss or damage, direct or indirect, that may arise as a result of a breach of this obligation. In the event that the data provided belong to a third party, as a User you must ensure that you have informed the third party of the aspects contained in this document, and obtained their authorization to provide their data to LUZIA for the purposes indicated.

Therefore, it is important to inform that LUZIA complies with the data protection regulations of the countries in which we operate, or direct our services, which are mainly Argentina, Brazil, Colombia, Spain, Chile and Mexico. Because of this, there may be specific amendments referred to in this privacy policy that apply to you only if you are a user of the countries referred to above and, in some cases, different rules may be established due to applicable local legislation. In the event of a conflict, the specific amendment will prevail.

1.Controller for the Processing of Personal Data

The data processing is carried out by and on behalf of FACTORÍA ELCANO, S.L. (hereinafter "LUZIA"), who collects your data, domiciled in Madrid (Spain), at Marqués de la Ensenada 2 - 28004 Madrid, and provided with CIF B13883186.

If you wish to contact us with any questions, please write an email to [e-mail], and we will get back to you as soon as possible.

For any question related to this privacy policy, as a User, you may contact our data protection officer by e-mail: [e-mail] .

2.What are the purposes of the processing and lawfulness?

From LUZIA we would like to explain that we will only process your personal data for the purposes explained below.

In the event that you use our AI tool as a User, either through WhatsApp, Telegram or through the App (hereinafter, "Tool" or "Platform"), we will carry out the following purposes:

• We will process your personal data to manage your registration, as well as your user preferences within your account, and to provide you with the services you have requested. The lawfulness that enables LUZIA to process your data for this purpose is your registration request and with it your consent. In the same way, we inform you that your data will be retained until you cancel your account with us;
• We will also treat your data to ensure the proper use of our services, preventing illegal uses or contrary to our policy and values, and may even unsubscribe you as a registered user. The legitimate basis for such treatment is compliance by LUZIA of certain legal obligations, as well as the legitimate interest of protecting our services and business interests. The data will be retained during the processing of personal data and to comply with legal obligations;
• Show you publications that are of interest to you because of the use of our application or website. The basis of legitimacy to carry out this treatment will be the legitimate interest;
• Send you, by any means, including electronic means, communications in relation to services offered by LUZIA, communications that may be addressed in response to your consumption habits, browsing or use of our website and / or our Tool. LUZIA will perform such treatment in response to the relationship with you, taking into account that such communications will always be about our services. The data will be retained as long as necessary to ensure this purpose, however you can oppose this treatment at any time;
• Manage your participation in the contests we organize in accordance with our legal bases. The basis of legitimacy for this treatment will be your express consent to participate in the contests we promote. Those data collected to send you commercial communications about our own services will be kept as long as you do not unsubscribe as a registered user and do not oppose to such treatment;
• Manage the improvement and development of the Application. From Luzia we may treat pseudonymized or anonymized data to improve our tool and optimize your user experience, in this sense, the basis of legitimacy will be the legitimate interest;
• Manage complaints and inquiries about the services offered through our website and / or our Tool. The legitimate basis for this treatment is the legal obligation of LUZIA in accordance with the regulations for the protection of consumers and users. Those data obtained as a result of complaints or queries that you can direct to us will be retained until the complaint or query has been resolved, or for a period of 5 years to ensure the reliability of the same;
• LUZIA has implemented a chat functionality that allows users to interact with each other within the platform. In order to guarantee a proper use and to prevent illicit or abusive behaviors, LUZIA treats users' personal data, based on legal obligations and on its legitimate interest to protect its services; this functionality is currently available in Brazil and Colombia. ;
• If you have provided us with your express consent for this purpose, we will communicate your data to third party companies outside LUZIA, in order to show you advertising tailored to your preferences of consumption and navigation of both our services and third parties. The lawfulness to carry out this processing will be the express consent, and we will keep the data as long as necessary to carry out the process or until you object to it.

The acceptance as User of your personal data that may be processed or transferred will always be revocable, without retroactive effect. To revoke such consent you may do so through [e-mail] .

We are not responsible for the privacy practices of any platform, website or application not controlled by us.

The personal data provided is processed and retained to the extent necessary to maintain the purpose for which it was collected or for as long as necessary to fulfill our contractual or legal obligations or any other permitted purpose for which we have collected it, including the prevention of fraud, abuse, potential crime, law enforcement requests or security incidents. After the applicable retention period has expired, we will take reasonable steps to block or delete such information.

Once the reason for which the data were processed has ended, they will be deleted or anonymized in accordance with the provisions of the regulations on the protection of personal data, which will involve, where appropriate, blocking the data without access, so that they can only be available at the request of the competent authorities with powers to demand access (for example, Security Forces and Corps, Judges and Courts) and during the period of limitation of any actions that may arise; once this period has elapsed, they shall be completely deleted.

3. With whom do we share your personal data?

The processing of your personal data may be carried out by third parties contracted by LUZIA. These providers will only process the data for the purposes set out in the preceding paragraph, and following precise instructions, in strict compliance with the laws on protection of personal data, information security and other applicable rules. Therefore, such communication of data can be legitimized on the basis of a legal obligation, contract or express consent.

Personal data may be shared in the following circumstances:

• to a buyer or other successor in the event of a merger, spin-off, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets; if we believe disclosure is necessary or appropriate to protect our rights, property or interests, our investors or others;
• to contractors, service providers and other third parties that we use to support our Application; currently our vendors include. WhatsApp LLC, Telegram, OpenAI and Stability AI, but they do not access the personal data on the Application that we have shared with them.
• to fulfill any purpose for which it was provided to us;
• for any other purpose that you are informed of when you provide us with the information;
• to comply with any court order, law or legal process, including responding to any governmental or regulatory request;

For the performance of certain processes, for example, the storage of data in cloud systems, personal data is processed and hosted on AMAZON WEB SERVICES servers that are located within the territory of the European Economic Area (EEA) and therefore do not have the status of international data transfer under the GDPR.

Certain personal data necessary to provide the Services offered by LUZIA Spain may be shared with:

• Our suppliers when required by the activity, in which case we will inform the recipients, the purpose and the retention period of their data.
• Law enforcement agencies, judges and courts, when necessary in compliance with a legal obligation.

4. What are my data subjects rights and how can I exercise them?

As a user of LUZIA you have the right to obtain information about your personal data and how we are processing them.

4.1. Europe:

In the event that you are an EU resident, the data subjects set out in the GDPR apply to you, and these are as follows:

• Right of access: you have the right to request copies of your personal data.
• Right of rectification: as a user, you have the right to request that we correct any information that you believe is inaccurate. You also have the right to request that we complete information that you consider incomplete.
• Right of erasure: you have the right to request that we delete your personal data in certain circumstances.
• Right to restrict processing: you have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to object: you have the right to object to the processing of your personal data in certain circumstances.
• Right to data portability: You have the right to request that we transfer data we have collected to another organization, or directly to you upon request, in certain circumstances.

To exercise the aforementioned rights you must send an email to: [e-mail]. When doing so, please provide the following information:

Name and surname

Right you wish to exercise

Data on which your request is based

We will resolve your request within a maximum period of one month, notifying you by e-mail.

We inform you that you have the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es) in the event that the exercise of your rights here indicated have not been satisfied.

Under the California Consumer Privacy Act (CCPA), California residents have the right to request a notice from us identifying the categories of customer personal information that we share with certain third parties for marketing purposes, and providing contact information for those third parties.

If you are a California resident and would like to receive a copy of this notice, please send us a written request by email to [e-mail] . You must include in your request the statement "Your California Privacy Rights" and your name, address, city, state and zip code. We are not responsible for notices that are not labeled or sent properly, or that do not contain complete information.

If applicable, you have rights to:

• to know the categories of personal information collected in the previous 12 months, as well as its sources and business purpose;
• know if your personal information has been sold or disclosed, and to whom, in the previous 12 months;
• in case of "sale" of information, the right to object to the sale of your personal information;
• access and delete your personal information (subject to exceptions); and
• equal service and price (non-discrimination) if you exercise your privacy rights.

In this case you have the following rights:

• Rights to ensure: for identity verification purposes, LUZIA requires the user to submit a deletion request providing your full name as well as your email address in relation to your account. LUZIA will send you a verification email, in which you must re-authenticate the deletion request.
• Do not sell my information. We take your privacy seriously. We do not sell our members' information. We are not a data broker.

The Lei Geral de Proteção de Dados (LGPD) is a legal framework that regulates the collection and use of personal data of residents in Brazil. If the LGPD applies to you, you have the right to:

• confirm the processing of your personal data;
• access to your personal data;
• rectify incomplete, incorrect or outdated personal data;
• request anonymization of your data, blocking or deletion of unnecessary, excessive or non-compliant personal data;
• request that a data controller transfer your personal data to another service or product provider (data portability);
• delete your personal data (with exceptions);
• receive information about the public or private entities with which your personal data has been shared and how this has been done;
• receive information about your right not to consent to the processing of your personal data and the consequences of your refusal; and
• revoke your consent to the processing of your personal data.

If you wish to exercise any right, please contact us at [e-mail] to exercise your rights under the LGPD.

You may also file a complaint about any of the above rights with the Brazilian National Data Protection Agency (ANPD), as well as with the competent consumer rights authorities (PROCON) in your Brazilian State of residence.

4.4. Colombia, Argentina, Mexico and Chile

Users residing in Argentina, Colombia, Mexico and Chile are entitled to exercise the following rights:

• Right of access: you have the right to request copies of your personal data.
• Right of rectification: as a user, you have the right to request that we correct any information that you believe is inaccurate. You also have the right to request that we complete information that you believe is incomplete.
• Right of erasure: you have the right to request that we delete your personal data in certain circumstances.

You can address your communications and exercise your rights by sending a written communication to the following e-mail address [e-mail] . In some cases, the request may be denied if the deletion of data necessary for compliance with legal obligations is requested.

4.5. United Kingdom

The current UK regulations provide our UK users with the same rights as European citizens in terms of data protection. If you are a UK resident, you can exercise your data protection rights by sending an email to [e-mail], and they are as follows:

• Be informed about how your data is used
• Access to personal data
• Cause incorrect data to be updated
• Stop or restrict the processing of your data
• Data portability (allowing you to obtain and reuse your data for different services)
• object to the processing of your data in certain circumstances

5. What personal data do we collect?

The personal information we request from you and the reasons for the request will be clearly explained to you at the time you provide your personal information. If you contact us directly, we may receive additional information about you, such as your name, e-mail address, telephone number, the content of the message and/or attachments you send us, and any other information you choose to provide.

When you register for a LUZIA account, we will ask you for the following information:

• Name or nickname (phrase or emoji)
• E-mail address

When you use your LUZIA account, please note that we may collect the following information:

• access time;
• IP address;
• application information;
• information from the mobile device;
• Session ID; and
• any information you send through the Chat functionality of the Application.

Please note that LUZIA uses some automated processes to evaluate how we can best meet your requests and it is therefore essential that you are informed of this.

Finally we emphasize the fact that the data that we may request, in general, are necessary to fulfill the purposes of our services, so if they are not provided or not done correctly, we will not be able to meet your requests.

6. Additional Information

6.1 Safety measures

We want to inform you that from LUZIA we respect your privacy, and we have taken the necessary measures to prevent alteration, loss, unauthorized access or processing of personal data, taking into account at all times the state of technology, however, as a user you should be aware that Internet security measures are not impregnable.

6.3. Minors.

As a user you must be at least 13 years old if you register in any country belonging to LATAM, and if you are registered as a user in Europe you must be at least 14 years old, but in both cases you must be old enough to be able to register for instant messaging services or use them without parental control in your country. If according to the applicable legislation in your country, as a User you do not have full legal capacity to consent and act (in Spain, 18 years), your parents or legal guardians must accept these Terms on your behalf.

Important: In case of navigation or use by a minor, Luzia Spain will not be in any case responsible and the legal guardians of the minor must assume control and supervision during use, as well as responsibility for the actions of the minor. Another of our priorities is the protection of minors in the use of the Internet. We encourage parents and guardians to observe, participate in and/or supervise and guide their children's online activity. If you believe that your child under the age of 18 has provided such information on our website, we strongly encourage you to contact us immediately and we will use our best efforts to promptly remove such information from our records.

6.4.Contact with LUZIA

For any questions or comments regarding this Privacy Policy or the way in which LUZIA collects and uses your Data, you can contact us via e-mail: [e-mail] .

This Privacy Policy was last updated on July 2024. In any case, we suggest that you review this Privacy Policy from time to time in case there are minor changes or we introduce any interactive improvements, taking advantage of the fact that you will always find it as a permanent point of information on our Web and our App.

6.5. Privacy Policy Update

From LUZIA we reserve the right to modify the content of this Privacy Policy, the changes will be made public on this website. The relationship with users will be governed and bound in accordance with the policies that are publicly exposed at the precise moment when the user accesses the Application or web luzia.com.

Summary

Privacy Policy

You are about to read a very brief summary of our Privacy Policy. We strongly recommend that you read the full information afterwards to get all the details.

• Your privacy matters: We respect your privacy and protect your personal data. Luzia is not trained with your conversations.
• Why we collect data: To manage your account, improve our services and communicate with you. Currently we only collect your phone number or email and your name.
• Keeping data secure: We follow strict laws and use strong security measures, but no system is foolproof.
• Your control: You can access, correct or delete your data at any time. You have total control.
• Who sees your data: Only when necessary or with your consent, we share data with trusted, fully compliant third parties. Your data is completely anonymous and not linked to you.
• Stay up to date: We update our policy from time to time. Check our site regularly for the latest information.