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PRIVACY POLICY The privacy policy set forth in this legal text is documented for the purpose of informing users of the website about the terms under which the processing of personal data is carried out, as collected in connection with the contracting of services provided by the owner of the site and in compliance with the duty of information and transparency under the European General Data Protection Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD). 1.- IDENTIFYING DATA OF THE DATA CONTROLLER Data Controller: PABLO MARÍ DOMÉNECH (HACELERIX) NIF: 23825152-G Registered Address: Azagador de las Monjas, 1 Dplo – 46018 - Valencia (Valencia) Email: info@hacelerix.com Website: hacelerix.com Main activity: agency specializing in the development of AI systems for the automatic generation of content for social media DPO Contact: info@autranconsultores.com 2.- USER INFORMATION AND CONSENT The contracting of services provided by the website owner requires the provision of personal data and entails the need to register, store and process such data. Failure to provide certain information may prevent the provision of services or the execution of procedures related to the contracting of those services. According to the GDPR and the LOPDGDD, by accepting this Privacy Policy upon contracting services, users give their express, free, informed and unequivocal consent for the personal data they may provide via forms or other enabled means to be incorporated into the files of the website owner and processed for the purposes outlined in this Privacy Policy. The data controller informs users that, in compliance with applicable regulations, appropriate technical and organizational security measures have been applied to the personal data processing activities, following a thorough risk assessment. 3.- CATEGORIES OF PERSONAL DATA COLLECTED We collect only identifying information, contact details, financial and economic data, and personal characteristics. Where applicable, we may also collect professional information related to jobs, positions, or roles held by users. In general, and in accordance with the principle of data minimization, only strictly necessary data are collected to manage service requests, free trials, suggestions, inquiries, or information requests submitted by users via the contact means available on the website or through other public means. We do not collect sensitive or specially protected personal data as they are not relevant for the provision of services. 4.- PURPOSES FOR WHICH PERSONAL DATA ARE PROCESSED The personal data collected through the contact means on the website or in connection with service contracting are processed for specific purposes, as described below: - Data collected via contact channels (for inquiries, information requests, free demonstrations, professional contact): used to respond to requests and/or provide specific information requested by users. Only the necessary data will be collected. - Data required for service contracting and administration: used for administrative purposes, payment processing, and service execution. Only the necessary data will be requested to manage the specific service requested and prevent fraudulent or illegal activity. - Data for user registration: used to manage user accounts following the protocols and tools enabled for such registration. - Data for quotes and proposals: used to prepare personalized quotes and provide information about service pricing and contracting conditions. - Data for commercial communications: used to send promotional or commercial information explicitly requested or previously accepted as part of service contracting, and always related to the contracted services. Users can revoke consent or object to such processing. At any time, personal data may be requested from users through forms or other contact methods, in which case this Privacy Policy shall apply. 5.- LEGAL BASIS FOR DATA PROCESSING The legal basis for processing personal data depends on the purpose and is described as follows: - For inquiries, information requests, demonstrations, suggestions, or professional contact: user consent, which may be withdrawn at any time by emailing info@hacelerix.com - For service contracting: the performance of a contract or pre-contractual measures (Art. 6.b GDPR). - For user registration: performance of a contract and user consent, which can be withdrawn (Art. 7 GDPR). - For quotes and offers: user consent, which can be withdrawn. - For commercial communications: express and informed user consent under the terms of Art. 7 GDPR, which can also be withdrawn at any time. 6.- DATA RETENTION PERIOD Personal data will be recorded, stored, and processed while the service relationship is maintained and the data are needed for performing activities and fulfilling the purposes described in section 4. If users request data deletion or revoke their consent, processing will cease as legally required. Once the contractual or business relationship ends, legal retention periods apply: 5 years for general personal actions, 6 years for invoices and accounting records, and 10 years under anti-money laundering regulations. During the retention period, data will be blocked and accessible only to public authorities. Once this period ends, the data will be permanently deleted. 7.- DATA QUALITY HACELERIX reminds users that unless legally represented, no user may use another person's identity or submit their data. Users may only submit their own personal data or that of legally represented parties, and must ensure such data are appropriate, accurate, current, and truthful. Users are responsible for any damages caused to third parties or HACELERIX from misuse or unauthorized use of personal data, including the use of false, outdated, or incorrect personal data. Users submitting third-party data must have obtained the informed consent of those third parties under this Privacy Policy and will be liable for doing so. 8.- RIGHTS OF DATA SUBJECTS According to the General Data Protection Regulation (EU) 2016/679 and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, individuals may exercise the rights granted by applicable regulations regarding their personal data, specifically: - Right of access: to confirm whether personal data concerning them is being processed, access such data if so, and receive full information on the processing carried out by the website owner (Art. 15 GDPR). - Right to rectification: to correct inaccurate personal data without undue delay and complete any incomplete data (Art. 16 GDPR). - Right to erasure: to have personal data erased without undue delay under the circumstances provided in Art. 17 GDPR, particularly when the data are no longer needed for their original purpose. - Right to restriction of processing: when the conditions indicated in Art. 18 GDPR are met, such as disputing data accuracy or pending a decision on a legitimate basis for processing. - Right to data portability: to receive personal data in a structured, commonly used, machine-readable format and transmit it to another controller (Art. 20 GDPR). - Right to object: to oppose the processing of personal data for reasons related to their particular situation, in the cases provided in Art. 21 GDPR. - Right to withdraw consent: at any time, without affecting the legality of processing based on prior consent (Art. 7 GDPR). To exercise the right to withdraw consent for any processing that required it, users can simply send an email to: info@hacelerix.com If users believe their personal data have not been processed in accordance with applicable laws, or if their rights requests have not been satisfied, they may file a complaint with the Spanish Data Protection Agency (AEPD), located at Calle Jorge Juan, 6 – 28001 – Madrid, or through its contact channels available on www.aepd.es and its electronic headquarters: https://sedeagpd.gob.es/sede-electronica-web/ To exercise any of the above rights, users may request the appropriate form from HACELERIX by using the contact information provided above. The form must be accompanied by a copy of their ID card or equivalent document proving their identity and, where applicable, that of their legal representative. Exercising these rights is free of charge. Requests may be submitted in person, by post, or via email to the contact addresses provided. HACELERIX has established and implemented specific protocols and measures to comply with the data protection rules of Regulation (EU) 2016/679 and Organic Law 3/2018. 9.- USER RIGHTS REGARDING COMMERCIAL COMMUNICATIONS HACELERIX informs users that those who have expressly authorized the sending of commercial or promotional communications via email, SMS, or any equivalent electronic communication method (e.g. newsletters), have the right to object to the processing of their personal data for such purposes or revoke their consent by simply notifying HACELERIX at: info@hacelerix.com 10.- RECIPIENTS OF PERSONAL DATA Personal data provided by users will generally be processed only by HACELERIX, the website owner, and specifically by authorized staff or independent collaborators under confidentiality agreements and subject to data secrecy obligations. In general, personal data will only be disclosed to third parties with the user’s consent or when legally required, such as to public authorities, law enforcement, or the courts. Data may also be shared when necessary for the execution of the contracted services and to support website operations, including third-party providers such as banks, payment processors, and technical service providers. These will be bound by data processing agreements or collaboration contracts with HACELERIX. HACELERIX is committed to informing users if extraordinary data transfers are required, so users may give prior consent before such transfer takes place. 11.- INTERNATIONAL DATA TRANSFERS There are no plans to disclose or transfer personal data to recipients located outside the European Economic Area. However, if international data transfers become necessary due to the use of tools, applications, software, or service providers, such transfers will be carried out with appropriate safeguards, under the current international agreements, standard contractual clauses, or binding corporate rules that ensure software companies outside the EU comply with European data protection policies regarding privacy, confidentiality, and data security. 12.- DATA SECURITY AND CONFIDENTIALITY HACELERIX is committed to the proper use and processing of users' personal data, respecting their confidentiality, and using such data only for the purposes outlined in this Privacy Policy. HACELERIX will fulfill its duty to protect personal data by adopting and applying all necessary measures to prevent alteration, loss, unauthorized access, or processing, in accordance with current data protection regulations. This website uses a security protocol that ensures data are transmitted securely and in full. Communication between users and the server, and vice versa, is encrypted. HACELERIX cannot guarantee the absolute security of the Internet and, therefore, cannot prevent potential data breaches through fraudulent access by third parties. Regarding data confidentiality, HACELERIX ensures that all individuals authorized to process client or user data—including staff, collaborators, and service providers—are bound by the appropriate confidentiality obligations, whether legal or contractual. If a security incident occurs, HACELERIX will notify affected users without undue delay and will provide timely information regarding the incident, as well as any additional information reasonably requested by users. 13.- DATA ACCURACY AND TRUTHFULNESS Users are solely responsible for the accuracy and correctness of the personal data they submit to HACELERIX, thereby releasing the website owner from any responsibility in this regard. Users guarantee and are responsible for the accuracy, truthfulness, validity, and authenticity of the personal data provided, and commit to keeping them updated. Users agree to provide complete and correct information through the available contact channels on the website. 14.- CHANGES TO THIS PRIVACY POLICY HACELERIX reserves the right to modify this Privacy Policy in order to adapt it to legislative or jurisprudential changes, as well as to industry practices. In such cases, changes will be announced on the website well in advance of their implementation. Privacy Policy last updated on June 2, 2025.