Privacy Policy 

https://circularpass.io/

Version: December 2024

1. PURPOSE OF THE PRIVACY POLICY 

The objective of the company BLUE ROOM INNOVATION SL (here in after "BLUE ROOM", or the "Provider"), through the website https://circularpass.io/ (here in after, the "Website"), is to offer the user (the "User") a safe and reliable browsing experience and service through it and what is displayed or collected through it. 

For this reason, we have implemented this Privacy Policy, which complies with the guidelines and security measures required by Organic Law 3/2018, of December 5 , on the Protection of Personal Data and guarantee of digital rights, and by the European Data Protection Regulation 679/2016, of April 27, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data, all with the aim of guaranteeing privacy and being transparent with the use of user data.  

2. DATA CONTROLLER AND CONTACT INFORMATION

As already stated in the Legal Notice , the person behind this Website and, as regards data processing, considered responsible for the processing, is: 

BLUE ROOM INNOVATION SL

NIF: B55237689

Registered office: Calle Gran Via Carles III, 98 - Floor 10, 08028, Barcelona

Contact email: info@circularpass.io

Data protection email: lopd@blueroominnovation.com

Contact phone number: +34 630 450 536

Registration data: registered in the Barcelona Commercial Registry, Volume 3033, Folio 213, Page GI-58697.

For any information you may need as a User in relation to this privacy policy, you may contact us at the email address indicated above or at our physical address. 

3. IN WHICH SECTIONS OF OUR WEBSITE DO WE COLLECT YOUR PERSONAL DATA?

3.1. Corporate emails 

You can write to us and/or request any information you need to clarify any doubts you may have regarding our services, the operation of our Website or our data protection policy by using our email addresses: info@circularpass.io and/or lopd@blueroominnovation.com. Furthermore, in the “Work with us” section of the Website, the User may contact us for this purpose via the email address info@circularpass.io if he or she is interested in working for us. 

3.2. Contact with the company

The User may contact us to channel their doubts, queries, comments or any other communication they wish through the email info@circularpass.io or the following telephone number: +34 630 450 536.

3.3. Forms

We may collect personal data from the User through our Website. The collection of this data will take place when the User enters information in the fields designated for that purpose, which will be clearly indicated. These forms will not collect any data until the User has given his/her consent for the processing of his/her information, in accordance with this Privacy Policy. 

3.4. Behavior and habits on the Website

Likewise, we may collect information regarding your behavior on the Website through cookies. In this regard, we inform you that you can consult our Cookies Policy  for more details. 

4. NEWSLETTER AND COMMERCIAL COMMUNICATIONS 

We offer the User the possibility of subscribing to our Newsletter and receiving commercial communications from us by email. By subscribing, the User gives his/her express consent to receive information about our latest news, events and developments in our company or in the sector. The User may unsubscribe from this service at any time; for this purpose, each email sent will include a simple and clear link to unsubscribe, allowing the User to withdraw his/her consent easily and free of charge.

The communications will include relevant and up-to-date information about our services, events, promotions and news of interest related to our company. The information collected for sending the Newsletter will be used exclusively for this purpose and will not be shared with third parties without your explicit consent, except in cases required by law.

5. WHAT IS THE OBJECTIVE AND/OR PURPOSE OF DATA COLLECTION?

The purpose of data collection in all the sections mentioned in the previous point is:

● Maintain direct and personalized contact with our Users. In this way, we will use your data to answer any questions or provide any information you have requested, manage your requests and guarantee an experience that meets the highest standards.

● Manage your commercial relationship with https://circularpass.io/ . We may also use your data for advertising, commercial prospecting and marketing purposes, to send information about CircularPass, our events, initiatives, promotions or current sector news, if you expressly give your consent at the indicated time and in accordance with the information provided in this Privacy Policy.

● We use the email from which you write to our corporate email to send you information related to the questions or concerns you have raised, as appropriate.

Under no circumstances will you receive information from third parties without having been informed and having previously requested your consent, thus ensuring compliance with the parameters of Spanish law and European regulations.

Users are also informed that we will not carry out international transfers of their data, except for the exceptions set out in our legal texts, where applicable. All the servers we use to provide the services are located within the European Economic Area.

We will send you information about our company, its actions, events, collaborations with third parties, commercial actions and/or any other initiative related to the company depending on the type of consent that you grant us. 

6. USE OF PERSONAL DATA AND COMMERCIAL PURPOSES

BLUE ROOM informs its Users that the personal data they provide us will be processed for the purposes set out in point 1 and which will be, in detail, the following: 

1. Respond to and resolve any requests or queries required by Users;

2. Inform you of any new developments that we may have available both on the Website and in the company; 

3. Send information that is considered to be of interest to the User;

4. Send information about CircularPass news and updates;

5. Your data will not be used for purposes other than carrying out the processing for which you expressly consented at the time or for the purposes established in this policy on our part; all this information is stored on an independent secure server. 

We would like to inform you that the information you provide through the Website may reveal or allow others to deduce your nationality, ethnicity, sex, age or other aspects of your private life. Therefore, by providing this information completely voluntarily through any means of our Website, you are expressly and voluntarily accepting this Privacy and Personal Data Protection Policy.

7. SHARING INFORMATION WITH THIRD PARTIES

As already established in the previous points, BLUE ROOM will not provide User data to third parties, understood as third parties that have no direct link with the User or that do not carry out a function on behalf of or at the request of the service provider or data controller, that is, BLUE ROOM, except by legal obligation or with those entities that act as Data Processors or other companies in the group. In both cases, we guarantee that we take the necessary measures to protect User data, including the signing of a contract that provides for this in accordance with the regulations. If you wish to do so, you will be informed in advance and your consent will be requested.

BLUE ROOM does not provide User data to any other third party, except in a limited manner where indicated in one of our legal texts (e.g. in our Cookies Policy ).

8. LEGAL BASIS: EXPRESS CONSENT FOR THE PROCESSING OF YOUR DATA

8.1. Consent of natural persons

In compliance with the requirements of Organic Law 3/2018, of December 5 , on the Protection of Personal Data and guarantee of digital rights, and the European Data Protection Regulation 679/2016 and in accordance with the provisions of our internal policies, each time the User sends us personal data, they must give their express consent by clicking on the box that appears at the bottom of each form where their data is collected, or when they write to us at our contact email or any other email enabled for specific functionalities of the Website, they will be expressly accepting that we can collect their data for the purpose or request that they have indicated to us. With said action(s), they are freely and unequivocally stating that they agree that BLUE ROOM processes their data for the purposes mentioned in the previous sections.

Likewise, the User guarantees that the personal data provided to BLUE ROOM are true and is responsible for communicating any changes to them.

The User's acceptance that his/her data will be processed for the purposes referred to in this policy is always revocable, without retroactive effect, in accordance with the provisions of current legislation; therefore, the User has the right to withdraw his/her consent at any time, without affecting the legality of the processing based on his/her prior consent, through the means provided in section 6 of this legal text.

8.2. Age of majority 

To be a User of our Website, as well as to use our services, it is necessary to be of legal age and have the corresponding legal capacity to act. 

8.3. Legitimate interest

Likewise, we may process the User's data based on our legitimate interest in accordance with the applicable data protection regulations, as duly informed to you at any time or in this Privacy Policy.

9. ON THE EXERCISE OF RIGHTS 

Organic Law 3/2018, of December 5 , on the Protection of Personal Data and guarantee of digital rights and the European Data Protection Regulation 679/2016, have implemented a series of legal guarantees that allow the User to exercise rights and actions related to the processing of their data.

BLUE ROOM offers you this legal guarantee, whereby, at any time and/or whenever you deem it appropriate, you may exercise your rights of Access, Rectification, Deletion, Opposition, Portability, Forgetting, Limitation in processing and not being subject to automated individual decisions, by writing to the contact email address we have provided for this purpose: lopd@blueroominnovation.com or by sending us a request by physical mail to Calle Gran Via Carles III, 98 - Piso 10, 08028, Barcelona, ​​proving or justifying your identity and expressly indicating in the subject the request you wish to make: access, rectification, deletion, opposition, portability, forgetting, limitation in processing or not being subject to automated individual decisions.

It is important that as a User you take into account that the information you have shared with Users by any means may continue to be visible and that BLUE ROOM is exonerated from all responsibility in relation to the elimination of this information.

Likewise, BLUE ROOM does not control the renewal system of third-party search engines, and said mechanisms may contain certain information from the public profile that has already been cancelled but is still on the Internet due to its rebroadcasting, in which case, we recommend that you contact the persons responsible for these platforms to request its cancellation or the exercise of a right to be forgotten.

Below we briefly explain each of the rights you can exercise:

Access by exercising this right you can find out what personal data of yours is being processed by us, its purpose, origin or its possible transfer to third parties.

Rectification This means that you can modify your personal data whenever it is inaccurate or incomplete, and you must specify in the request which data you wish to be modified.

Deletion Allows the cancellation of your personal data due to inadequacy or excessiveness.

Opposition With the right to object, you can object to the processing of your data in cases such as: advertising and commercial prospecting activities or when said processing is intended to make a decision concerning you, based solely on automated processing of your personal data.

Portability You may receive your personal data provided in a structured, commonly used and machine-readable format, and be able to transmit it to another controller, provided that it is technically possible.

You may request the deletion of your personal data without undue delay when any of the above-mentioned circumstances apply. For example, unlawful processing of data, or when the purpose that motivated the processing or collection has disappeared.

Limitation of processing In general, in cases where it is not clear whether personal data should be erased, you may exercise your right to limit processing. This right exists in the following cases: (i) when the accuracy of the data in question is in doubt; (ii) when as a User you do not want the data to be erased, (iii) when the data is no longer necessary for the original purpose, but cannot be erased for legal reasons, (iv) when the decision on your objection to processing is pending. 

Restriction means that your personal data may only (with the exception of storage) be processed with your consent for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of public interest of the EU or of a particular EU Member State. As a User, you must be informed before such restriction is lifted.

Not to be subject to automated individual decisions You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Likewise, as a User, you have the right to file a claim with the competent Control Authority, the AEPD ( https://www.aepd.es/es ), if you consider that the processing of personal data concerning you infringes the provisions of data protection legislation and regulations; all of this without prejudice to any other administrative appeal or legal action. 

You are also informed that the processing of your data will not be aimed at making decisions about your information based solely on automated processing -automated decisions-, nor will profiling be carried out, that is, it cannot include the creation of profiles in an automated manner -and without the use of human intervention actions- of your personal data to evaluate personal aspects relating to you, based on the data you provide us. 

Such processing shall be subject to appropriate safeguards, including information specific to you as the data subject and the right to obtain human intervention, where appropriate, to express your point of view, to receive an explanation of the decision taken following such assessment and to contest the decision, where appropriate.

10. SECURITY MEASURES IN DATA COLLECTION

To ensure security on the Website, we have integrated a security system that allows us to maintain the confidentiality and integrity of our Users' data that has been sent or collected through the means mentioned in the first point.

In this way, BLUE ROOM maintains the security levels of protection of your data required by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights and the European Data Protection Regulation 679/2016, of April 27, and has provided all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the data you provide through the Website.

Also, as a User, you understand, accept and comprehend that security measures on the Internet are not impregnable and that, therefore, you are obliged to adopt the necessary security measures that allow you to trust in the veracity of our Website, in which you are entering your data. We will also do our best to guarantee at all times the privacy and security of this personal information, always using the utmost diligence and implementing the measures that are necessary. 

Therefore, we inform you that you will be solely responsible for the security measures you implement in relation to the protection of your data, and therefore, BLUE ROOM is not responsible for situations where it has not implemented the corresponding security measures; nor for their consequences, as well as for causes or damages caused by third parties outside the business, including unforeseen events and/or force majeure.

In accordance with the above, BLUE ROOM cannot guarantee that unauthorized third parties may have knowledge of the type, conditions, characteristics and circumstances of the use that Users make of the services offered on the Website. However, as a measure, conditions of use have been provided in our Legal Notice .

11. PERSONAL DATA RETENTION PERIOD

The personal data provided will be kept for the time necessary to fulfill the purpose for which they were collected and to determine any potential liabilities that may arise from the purpose, in addition to the periods arising from applicable legislation.

12. COOKIES

We inform you that our Website uses cookies, of which the User is informed through the corresponding Cookies Policy .

13. MODIFICATION OF THIS PRIVACY POLICY

BLUE ROOM reserves the right to modify this policy to adapt it to future legislative or jurisprudential developments, as well as to future uses that it plans to make of the personal data of the Users of the Website. If said modification affects you in relation to the processing of your data, for example, because some additional processing of these data is going to be carried out, not previously informed, we will proceed to notify you of this. 

In any case, the User is advised to read the Privacy Policy or Personal Data Protection Policy of the Website each time he or she accesses it.

14. INTEGRATION WITH THE REST OF THE LEGAL TEXTS

This privacy policy is supplemented by the Legal Notice , the Cookies Policy   and other legal texts that may be applicable, where applicable. 

Last update: December 2024

© Copyright - BLUE ROOM INNOVATION S.L. - 2024