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PRIVACY POLICY
WILLCO LAB, S.L. (hereafter WILLCO) aims to respect the privacy of its users and protect the personal data that they may provide to WILLCO.
In accordance with Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights (hereafter LOPDGDD) and the European Union General Data Protection Regulation (hereafter GDPR), this data‑collection activity will be governed by the terms described below:
Information about the data controller, the purpose of processing, the legal basis and the retention period for personal data
This privacy policy contains all information about the personal data processing carried out by WILLCO on user data. As a sign of its commitment to data‑protection legislation, WILLCO permanently provides users with access to the privacy policy on this website.
WILLCO LAB, S.L. (hereafter WILLCO)
NIF: B‑87.978.300
Paseo de las Delicias, 106, Floor 6, Right Door
Madrid (28045 – Madrid)
willco.app
support@willco.app
Depending on how the user interacts with this website, WILLCO will need to process personal data, which will generally be the following:
- Identifying data (e.g. name, surname, language, contact details, etc.).
- Connection, location and browsing data (e.g. when interacting with us from a mobile device).
- Commercial information (e.g. if the user subscribes to our newsletter).
WILLCO reminds users that some of the personal data requested to access certain features or services on this website will be mandatory, as they are essential to provide the service, grant access to the functionality in question or manage the reason for their contact and process it administratively.
Depending on how the user interacts on this website, personal data will be processed for the following purposes:
| PURPOSE | INFORMATION |
|---|---|
| CUSTOMER SUPPORT | Process the personal data strictly necessary to manage or resolve the user’s query, request or petition. |
| MARKETING | Process personal data to manage the delivery of commercial communications, promotions or Newsletters to users who have subscribed. |
| QUALITY SURVEYS | Send quality surveys about the products or services provided. |
The user remains responsible for the truthfulness of the data supplied. If not, WILLCO may exclude the user from services where false data was provided, without prejudice to other legal actions that may apply.
The legal basis that permits the processing of personal data supplied by the user is governed by the following table:
| PURPOSE | LEGAL BASIS |
|---|---|
| CUSTOMER SUPPORT | When the user contacts us via any form enabled on this website or any other contact method advertised on this website, the legal basis is the user’s consent. Additionally, WILLCO has a legitimate interest to attend to the user’s requests, queries or concerns, whether through this website or any other contact channel, including social media where WILLCO is present. If the user’s contact with WILLCO is made in the exercise of rights protected by law, including complaints or enquiries related to WILLCO’s services or products, the legal basis is the fulfilment of legal obligations. If the data supplied are contact details of sole traders or professionals, the legal basis is legitimate interest, as stipulated in Article 19 of Organic Law 3/2018, 5 December, on the Protection of Personal Data and the Guarantee of Digital Rights, in relation to Article 6.1.f) of Regulation (EU) 2016/679 of the European Parliament and of the Council, 27 April 2016. |
| MARKETING | The legal basis for processing personal data for marketing purposes is the user’s consent. Where a prior contractual relationship exists and WILLCO lawfully obtained the recipient’s contact details and used them to send commercial communications about products or services similar to those originally contracted, the legal basis is legitimate interest, as set out in Article 21(2) of Law 34/2002, 11 July, on Information Society Services and e‑commerce. If the data supplied are contact details of sole traders or professionals, the legal basis is legitimate interest, as above. |
| QUALITY SURVEYS | WILLCO has a legitimate interest to conduct quality surveys of users to analyse satisfaction with this website, customer support quality or the products and/or services contracted. |
The retention period for personal data will depend on the purposes for which they were collected:
| PURPOSE | RETENTION PERIOD |
|---|---|
| CUSTOMER SUPPORT | Personal data processed for this purpose will be retained for as long as necessary to address the user’s query, request or petition. |
| MARKETING | Personal data processed for this purpose will be retained until the user indicates a wish to stop receiving commercial communications. In the case of Newsletters, the user may unsubscribe at any time by clicking the link at the end of the update email received. |
| QUALITY SURVEYS | Personal data processed for this purpose will be retained for as long as needed to carry out the appropriate actions to improve our service, products or the usability of this website, depending on the survey’s purpose, or until WILLCO anonymises the collected data. |
Users are informed that WILLCO will retain personal data, properly blocked, for as long as civil, commercial, administrative, criminal or fiscal responsibilities may arise, in compliance with current legislation and until the statute of limitations expires. After these periods, personal data will be deleted.
WILLCO informs that, to fulfil the aforementioned purposes, it is necessary for personal data of users to be provided to affiliated companies, as well as to companies that support us in the services we offer, as data processors, such as:
- Technology service providers
- Customer‑service related service providers
- Administration service providers for WILLCO
- Marketing and advertising service providers and collaborators
It is also conveyed that personal data may be communicated to Public Administrations when required by current law.
WILLCO discloses that it contracts some of the functions necessary for service delivery to processors located outside the EU. In such cases, we inform that data are transferred while maintaining the security of processed data, using appropriate tools for international data transfer, such as standard contractual clauses or any other timely legal measure that ensures an adequate level of protection of personal data.
Rights of users
Users who have supplied personal data for WILLCO to process have the following rights:
| RIGHT | DESCRIPTION |
|---|---|
| RIGHT OF ACCESS | The user has the right to obtain confirmation from WILLCO whether personal data concerning them are being processed, and to access the personal data held by WILLCO. |
| RIGHT OF RECTIFICATION | The user may request that WILLCO correct inaccurate personal data concerning them. They also have the right to have incomplete personal data completed, including by providing additional information. |
| RIGHT TO ERASE / RIGHT TO BE FORGOTTEN | The user has the right to have personal data concerning them erased, subject to the requirements set out in current legislation. |
| RIGHT TO LIMITATION | The user can request that WILLCO limit the processing of personal data, subject to the legal requirements. |
| RIGHT TO DATA PORTABILITY | The user may receive personal data concerning them from WILLCO in a structured, commonly used, machine‑readable format and transfer them to another controller when processing is based on consent or a contract and is carried out by automated means. |
| RIGHT TO OBJECT | The user may object to the processing of personal data concerning them when such processing is based on public interest or legitimate interest. In such cases, WILLCO will stop processing the data unless there are compelling legitimate reasons or the exercise or defence of potential claims. |
| RIGHT TO AUTOMATED DECISIONS | The user has the right not to be subject to decisions based solely on automated processing, including profiling, that have legal effects or significantly affect them, subject to legal requirements. |
| RIGHT TO COMPLAIN | The user may lodge a complaint with the Spanish Data Protection Agency if they believe the rights set out in this privacy policy have been infringed, or if the processing of personal data concerning them contravenes Regulation (EU) 2016/679 or Organic Law 3/2018. |
The user or their representative, whether legal or voluntary, upon proving their identity and the appropriate power of representation, may exercise the rights above by sending a written communication to support@willco.app.
Social Media
WILLCO is present on the main social networks: BlueSky, Facebook, LinkedIn, Instagram and X. For this reason, WILLCO acts as the data controller for data shared on its profiles derived from friends, likes, followers, comments, pins, etc.
Users expressly agree to be bound by the privacy terms and conditions of the social networks or platforms where WILLCO is present, authorising WILLCO to use the means that these networks allow to inform users about the various activities and services performed.
Minors
Users under 14 years old may not use the services available on this website without the prior authorisation of their parents, guardians or legal representatives, who will be solely responsible for all acts carried out through this website by minors under their care, including the completion of forms with the minor’s personal data and, where applicable, the marking of accompanying boxes.
In this regard, and as WILLCO cannot ascertain whether users are minors, parents, guardians or legal representatives must enable the necessary mechanisms to prevent minors from accessing this website or providing personal data without supervision; WILLCO accepts no responsibility in this regard.
Data Security
To guarantee the security and integrity of the personal data supplied, WILLCO has adopted the necessary technical and organisational measures to prevent data loss, as well as unauthorised processing or access by third parties, in line with current legislation and given the state of technology and the nature of stored data.
Changes to the privacy policy
This Privacy Policy may be updated at any time to meet the needs of the website and future legislative changes in privacy matters, with WILLCO reserving this exclusive right.
If such a modification is made, WILLCO will inform users of any significant changes that affect their privacy, allowing them to review the changes introduced, evaluate opposition to personal data processing or unsubscribe from a service or feature. In any case, if consent is required for the processing of personal data for purposes different from those described in this policy, consent will be sought in accordance with the prevailing data‑protection regulations.
Contact with WILLCO
Paseo de las Delicias, 106, Floor 6, Right Door
Madrid (28045 – Madrid)
support@willco.app