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PRIVACY POLICY

At Somhi Lagunak, SL we are committed to ensuring that your personal data is protected and not used for purposes other than those indicated in this Privacy Policy. For this reason, in this section we inform users and interested parties of everything concerning the processing of their personal data, thus complying with the data protection regulations applicable in our country: General Data Protection Regulation (EU) 2016/679, of April 27, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (hereinafter, ” RGPD” ) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (hereinafter, ” LOPDGDD” ).

This Privacy Policy applies to the data processing carried out by Somhi Lagunak, SL through this website: www.blablanote.community/ (hereinafter, the ” Website ”), the Blablanote App (” App ”) and/or any other information indicated. We recommend that you read it carefully before using this Website, App, or providing your data through them. You can contact us with any questions regarding this matter by emailing: legal@blablanote.com

TABLE OF CONTENTS

In this Policy, you will find all the information regarding the processing of your personal data and the rights you can exercise to maintain control over them. In this regard, you will find information about:

  1. Who is responsible for the processing of your data?

  2. What requirements must you meet to provide us with your personal data?

  3. What data processing do we carry out through the Website or App and what their main characteristics are, explaining:

    · What data we collect and how we collect it.

    · For what purposes do we collect the data we request from you?

    · What is the legitimacy for its processing.

    · How long we keep them.

  4. To which recipients your data is communicated.

  5. Existence of international transfers of your data.

  6. What your rights are and how you can exercise them.

  7. How we protect your personal information.

  8. Modifications to this policy.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Your personal data will be processed by the company Somhi Lagunak, SL (“Blablanote”), with NIF B22454987 and whose contact details are as follows:

2. WHAT REQUIREMENTS MUST YOU MEET TO PROVIDE US WITH YOUR PERSONAL DATA?

2.1. Minimum age. To provide us with your personal data, you must be at least 14 years old and/or, where applicable, have sufficient legal capacity to use this Website or App.

2.2. Truthfulness. When you provide us with your data to use our services, you guarantee that the data and information provided is real, truthful, up-to-date, and belongs to you and not to a third party.

In addition, you must notify us of any changes to the information you provide, and you are responsible for the truthfulness and accuracy of the information provided at all times.

2.3. Age and Veracity Checks. At Blablanote, we reserve the right to verify your age and identifying information at any time if necessary, including requesting an official ID or equivalent procedure. In the event of fraud detected, we confirm or suspect that you are under the stated age, and we may delete, temporarily deactivate, and/or cancel your account.

3. WHAT DATA PROCESSING DO WE CARRY OUT THROUGH THE WEBSITE OR APP AND WHAT ARE ITS MAIN FEATURES?

Below, we explain how we process your personal information and provide you with all relevant information regarding your privacy:

3.1. When you contact us through our channels (email):

What are the ways in which data is collected?

Sending emails to legal@blablanote.com , hola@blablanote.com , or other Blablanote email addresses.

What data do we collect?

Identification and contact information. We collect your identification information (first and last name) and email address, as well as any other information you voluntarily include in the communications you send us.

We may request additional information from you if necessary to fulfill your request or requirement.

What are the purposes of processing your personal data?

Respond to your requests. The main purpose of processing this data will be to respond to your requests, resolve your questions, and/or provide you with the information you require, as well as, where appropriate, follow up on your requests.

What is the legal basis that allows us to process your data? Is the provision of this data mandatory?

Consent. The data provided for the aforementioned purposes will be processed based on your consent, which you voluntarily give when you contact us through the means made available to you to request information or make a request.

The information you must provide will be indicated with an asterisk or similar. Without this information, we will not be able to respond to your inquiries or requests.

How long do we retain your information?

We will process all your personal information while your requests are being processed and, if necessary, to follow up on them. After this period, Blablanote will retain this information, which is blocked, for the periods established by law to address potential liabilities and demonstrate compliance with our obligations.

To whom do we share your personal information?

We do not make any additional transfers to carry out this processing other than those indicated, generally, in section 4. To whom do we transfer your personal information? In this regard, some channels through which you can contact us are managed by service providers, who act as Data Processors. You will find more information about how these service providers operate in section 4, mentioned above.

3.2. When you subscribe to our newsletter and other commercial communications:

What are the ways in which data is collected?

  • Newsletter subscription form;
  • Newsletter subscription box or receipt of commercial information in a web form;
  • Or: Data derived from the contractual relationship between the Parties.

What data do we collect?

Identification and contact information: To send commercial information electronically, we use the contact information you provide on the corresponding form for subscribing to our commercial communications (email address).

If you have a contractual relationship with us, we may use your email address information that we have available to us based on our contractual relationship.

What are the purposes of processing your personal data?

Sending publications and commercial communications related to our products/services: We may send you, electronically, our newsletter and other commercial communications related to our products and services.

What is the legal basis that allows us to process your data? Is the provision of this data mandatory?

Commercial communications are sent:

Based on our legitimate interest, due to the existence of a prior contractual relationship between the parties in accordance with the e-commerce regulations (LSSI); or

Based on your consent, requested at the time of registration on the specific form or by checking a corresponding box on the contact form

You may unsubscribe from these commercial communications at any time through the mechanism indicated in each email or by indicating your wish to unsubscribe by sending an email to legal@blablanote.com .

How long do we retain your information?

If the sending of commercial communications is based on your consent, we will retain the information for as long as you are subscribed to our distribution list for this type of information. Once you unsubscribe, it will remain blocked for the legally established periods to address potential liabilities.

If commercial information is sent based on our contractual relationship, we will retain all your personal information for the duration of the contractual relationship. Once the relationship ends, Blablanote will retain this information, which is blocked, for the periods established by law to address potential liabilities and demonstrate compliance with our obligations.

To whom do we share your personal information?

There are no specific transfers of your personal data to fulfill the purposes indicated in this section. However, we may use the services of email 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 service providers operate, see section 4. To whom do we share your personal information? > Service Providers).

3.3. When you maintain a contractual relationship with us (you register as a user of our services)

What are the ways in which data is collected?

Contracting for Blablanote Services (signing contracts, accepting terms and conditions, accepting quotes, or other legal acts).

What data do we collect?

Identification and contact information: We will process your first and last name, email address, the profile picture you upload to your user account, the language in which you choose to record voice notes, and your voice.

Other personal information: We will process information about the contacts you choose to add to the app, as well as content you voluntarily include in voice notes you record through our platform or voice notes you choose to save to it.

If the voice notes recorded or saved on our platform, or the contacts you voluntarily add, contain personal information of a third party (such as your voice or contact information), you guarantee that you have informed this third party of this Privacy Policy and that you have obtained their authorization to provide us with their personal information for the purposes indicated herein. Blablanote assumes no liability for your failure to comply with the provisions of this paragraph.

If any functionality intended to assist users with special needs is enabled, its use could provide us with information about your health data. Under no circumstances is Blablanote’s primary purpose for collecting this type of information, and its processing will be limited to what is essential for the provision of our services.

We offer you the option to register as a user through your Google or LinkedIn account, or any other account that may be enabled in the future. If you choose to register or log in through a social network or third-party account, we will have access to some of your information included in your public social network account, such as your name and other profile information. At the time of registration, the social network will inform you about the data that will be transmitted to us for registration and will explain the terms and conditions.

Image and web testimonial. We will only share your image, professional information (company and position), and your testimonial about using Blablanote on our website if you give us your consent.

What are the purposes of processing your personal data?

Register and manage your account so that we can provide you with access to our services.

Execute and maintain the contractual relationship between the Parties. The primary purpose of processing this data will be to maintain and execute the contractual relationship between the Parties, which may include: Administrative, tax, legal, accounting, and commercial management of customer data; handling inquiries and complaints via the web or electronically; and managing debt collections.

Share your experience using our platform on our website for commercial purposes.

Prevention, detection, and prosecution of illegal activities or activities that violate the Terms of Service or endanger the security of information or Blablanote. Blablanote may process data to monitor and prevent any form of abuse of our services, such as fraudulent activities, denial-of-service attacks, sending spam, unauthorized access to our users’ accounts, as well as any other practice that violates the General Terms and Conditions of Use of Blablanote or endangers the security of information or the integrity of Blablanote itself. Blablanote may also delete content or accounts that violate the law or our General Terms and Conditions.

Statistical and other purposes performed with anonymous data. We may anonymize all personal information collected from users who use Blablanote for statistical and other purposes, such as measuring the navigability and usability of Blablanote in order to improve the design, presentation, and available features.

What is the legal basis that allows us to process your data? Is the provision of this data mandatory?

Execution of the contract. Data processing is necessary for the execution of the contract between the parties.

All data requested and processed by Blablanote for the aforementioned purposes will be necessary for the purposes indicated. Failure to provide this data will prevent the services and associated administrative tasks from being executed.

Consent. We will only share information about your Blablanote testimonial if we have your consent to do so.

Only optional data such as your profile picture or contacts will be processed if you add them voluntarily and, therefore, based on your consent.

Legitimate interest. Data will be processed based on our legitimate interest in relation to: (i) the prevention of illegal activities and other activities related to the security of Blablanote, to ensure network and information security and prevent events that may compromise the availability, authenticity, integrity, and confidentiality of personal data or the platform itself, as well as compliance with the rules of use; and (ii) for statistical purposes and service improvement.

If you would like more information about how we have weighed Blablanote’s legitimate interests against the above purposes, you can request it by writing to us at legal@blablanote.com .

How long do we retain your information?

We will process all personal information for the duration of the contractual relationship between the parties. After this period, Blablanote will retain this information, which is blocked, for the periods established by law to address potential liabilities and demonstrate compliance with our obligations.

To whom do we share your personal information?

We do not make any additional transfers to carry out this processing other than those indicated, generally, in section 4. To whom do we transfer your personal information? In this regard, we may use service providers to provide certain auxiliary services (for example, management software), who act as Data Processors. You will find more information about how these service providers operate in section 4, mentioned above.

3.4. Browsing the Website (cookies)

On this Website, we use cookies and other tracking tools to collect information about how users use the Website.

For more information about the processing we perform through these tracking tools, please visit our Cookie Policy .

3.5. Blablanote profiles on social networks.

Blablanote has a profile on some social networks, such as LinkedIn or X.

When you follow one of our pages on social media, your data will be processed according to the terms of use, privacy policies, and access regulations of the corresponding social network, which you have previously accepted.

Blablanote, in this regard, will process your data for the purposes of properly managing its presence on the social network, informing you about activities, products, or services, as well as for any other purposes permitted by social network regulations.

Please note that we have no influence over the information collected by social networks or how they process it. Therefore, we recommend that you stay informed about the purpose and scope of the information collected through these social networks.

4. WHO DO WE TRANSFER YOUR PERSONAL INFORMATION TO?

Generally, Blablanote will not share your data with third parties. However, in addition to the transfers we specifically indicate in the section explaining the details of the different operations (point 3), we inform you of the communications we may make, in general terms, that affect all of the aforementioned processing and their legal basis.

  1. Providers of essential services to perform the service we offer you (for example, providers who provide us with information storage or voice note transcription services). Notwithstanding the foregoing, these entities have signed the corresponding confidentiality agreements and will only process your data according to our instructions. They may not use it for their own purposes or for purposes other than the service they provide to us.
  2. Public Bodies . We may disclose your data and any other information in our possession or accessible through our systems to the relevant public authorities when required by law, for example, to prevent or prosecute abuse of our services or fraudulent activities through our Website or App. In these cases, the personal data you provide will be retained and made available to the administrative or judicial authorities.
  3. In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or a portion of its assets, or any other corporate transaction involving a third party, we may share, disclose, or transfer user data to the successor entity (including during the pre-transaction phase).
  4. To third parties after aggregation or anonymization: We may disclose or use aggregated or anonymized data (i.e., data that cannot be linked to an identified or identifiable natural person) for any purpose.
  5. To third parties with the user’s consent or another legitimate basis: If we wish to share data with third parties outside the scope of this Privacy Policy, your consent will always be requested or you will be informed of the consent and its legitimate basis.

We also inform you that this Privacy Policy only addresses the collection, processing, and use of information (related to personal data) by us through your interaction with our Website or App. Access to third-party websites that you may access through links from the Website or App have their own privacy policies over which we have no control. Therefore, before providing them with any personal information, we recommend that you familiarize yourself with their Privacy Policies.