Privacy Policy

Privacy Policy - 2023

LIBERTY GLOBAL SOLUTIONS LTD (hereinafter, LIBERTY GLOBAL SOLUTIONS or Certified Mail Pro) as the Data Controller and of this website, in accordance with the provisions of Regulation (EU) 2016/679, General Data Protection and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights, provides you with this privacy policy in order to inform you, in detail, about how we treat your personal data and protect your privacy and the information you provide us with.

In this Privacy Policy we explain what your rights are regarding your personal information and how to exercise them. In addition, should you need to contact the competent authority for data protection, we will provide you with the contact details.

We, the data controllers of your data

Identity: LIBERTY GLOBAL SOLUTIONS LTD
TAX ID: 60040747S
Registered Office: Efesou, 9, Paralimni 5280, Cyprus.
E-mail: privacy@libertyglobalsolutions.com.

Our Data Protection Delegate (DPD)

The Data Protection Delegate is AURIS CONSULTORIA LEGAL I TRIBUTARIA S LIP. NIF B65951055, website: www.aurisadvocats.com.. If you have any type of query, doubt or suggestion in relation to how we use your personal data, you can contact the Data Protection Delegate at the following e-mail address: xavi@aurisadvocats.com

What kind of information may we collect about you?

The personal data we collect from users and customers can be grouped into the following categories:

Basic and Contact Data: such as first name, surname(s), ID card, NIE or passport number, user name or similar identifier, password, date of birth or gender. Also including your billing address, email and telephone number.
Financial and Economic data: this group would include details of payment, return and refund, as well as commercial transactions carried out with us. Including data to verify your identity for the acceptance of payments and the relevant financial checks to be able to carry out the commercial transactions.
Essential data to develop the service: minimum data requested by companies to cancel a service contract, including mobile phone companies, internet providers, television, energy supply companies, gyms or any other service provider that the user has contracted. By way of example and not limitation, the data requested may be invoices and contracts (rental, insurance, etc), a copy of the property deed, policy number, mutual card number, access codes to web portals and the user’s personal account.
Professional and employment data: this category would include your professional interests and your professional identity published online. For example, your LinkedIn profile.
Technical data: including IP addresses, registration data, browser and version used, time zone and usage, type of plugins installed in your browser, operating system and other technology used during access to our platform.
Browsing data: includes information relating to your browsing behaviour when you visit our platform.
Marketing and communication preferences: we collect your preferences to receive commercial communications and news from us, the consents given for this and the channel of your choice.

We will never collect personal data that is specially protected or considered sensitive!

How do we collect your personal data?

As a general rule, most of your personal information is provided to us directly from you. Either in person, by telephone, email, web forms or by responding to surveys. However, we may also obtain information from:

– Third parties connected to us, for example:
– A company of our group: LIBERTY GLOBAL SOLUTIONS LTD with NIF B67444869 and address at Efesou, 9, Paralimni 5280, Cyprus.
– From a third party that has previously obtained your expressed consent to do so, such as your bank or savings bank.
– From the cookies that we enable on our website – For further information on the use of our cookies, you can visit our Cookies Policy.

What can happen if you do not provide us with your personal information?

Where we are required by law to collect your personal data or, where it is essential for us to enter into a contract with you, in the event that you do not wish to provide us with your personal data, it may be impossible for us to serve you. In the event that we have to cancel the service because of this, we will first notify you when it is necessary to cancel the service.

For what purposes do we process your personal information?

We have added a detailed table with the purposes to which we collect your data and the legal basis on which we do this.

Purpose of processing
Why do we collect your information?

Legal entitlement to process your personal information

To provide you with our service, manage fees, accept payments and receivables due

(1) Contractual Performance
(2) Expressed consent of the person concerned

(1) Expressed consent of the person concerned
(2) Contractual Performance

To manage our relationship with our customers including:
(1) Notifying you of changes to our contracting conditions or policies
(2) Requesting you to respond to a survey or rate our services

(1) Contractual Performance
(2) Fulfilling a legal obligation
(3) In our legitimate self-interest (to update our records and to get feedback from our customers about our products/services)

Allow you to enter raffles or ask you to complete a satisfaction questionnaire.

In our legitimate interests (to study how customers use our products/services so that we can develop and improve our business).

To administer and protect our business and our websites. This includes detecting browsing problems, data analysis, web testing, etc.

(1) Fulfilling a legal obligation
(2) Legitimate self-interest (running our business, securing our networks, preventing fraud, etc)

Using analytical data to improve the web browsing experience, implement marketing strategies and optimise recruitment processes through the use of cookies.

(1) Own legitimate interest
(2) Consent of the person concerned (by accepting the use of analytical cookies, for example)

Suggest and recommend products and services that may be of interest to you.

(1) In our legitimate interest (to grow our business)

To prevent and detect fraud against you, our company or a company in our group.

In our own legitimate interest and in the interest of third parties, for example to minimise the damage caused by a scam.

To prevent unauthorised access and modifications to our systems.

(1) In our own and third parties’ legitimate interests. For example, to detect and prevent criminal acts that may be harmful to you and to us.
(2) In fulfilment of a legal obligation.

Responding to enquiries and/or providing information requested by the person concerned.

(1) Own legitimate interest
(2) Contractual performance
(3) Consent of the person concerned
(4) Fulfilment of a legal obligation

Manage user interactions on our social networks

(1) Fulfilling a legal obligation (to remove offensive, racist, profane or abusive comments; to maintain an atmosphere of respect and integration, to preserve the privacy of minors, etc)
(2) Legitimate self-interest (when we remove third party advertisements from our networks)

Providing personal information to the authorities or as required by law.

Fulfilling a legal obligation.

Notifying providers of cancellation of the user’s service or subscription

(1) Contractual performance

Providing information to users about the commercial services of Certified Mail Pro.

(1) Expressed consent of the person concerned

Resolving complaints, incidents or queries via the channels provided for this purpose: contact forms, email and customer service telephone number.

(1) Consent of the person concerned
(2) Contractual execution

To comply with legal, accounting, tax, administrative and contractual obligations related to the provision of the services requested.

Fulfilling a legal obligation.

To provide users with commercial information that may be of interest to them (unless they have objected to this, as indicated online by sending an email to the address privacy@libertyglobalsolutions.com under the subject “Unsubscribe newsletter”).

(1) With the expressed consent of the person concerned
(2) In his/her own legitimate interest (provided he/she has not expressed his/her wish to stop receiving communication, “opt-out”)

With whom may we share your personal information?

We may need to share your personal information with:

Our group companies: LIBERTY GLOBAL SOLUTIONS LTD.
Third party companies that we subcontract or service providers that we use to provide our services. For example, payment gateway providers such as Stripe.
Public or private companies that we notify of the cancellation of services or subscriptions by the user.
Third parties we need to run our business. For example, advertising agencies, lawyers, mutual insurance companies, etc.
The banks we work with.

All suppliers we work with are contractually bound to us. We can guarantee that they comply with all necessary security measures to safeguard your personal information, that they will use your personal data solely and exclusively for the specified purposes, in accordance with our instructions. We will also share personal information with law enforcement agencies when we are required to do so by law.

Where do we store your personal information?

All information you provide to us, whether through this website or through other means or channels, will be hosted on AMAZON WEB SERVICE servers. These servers are hosted within the European Economic Area.

International transfer of personal information

In order to provide service,we will sometimes need to transfer your data outside the European Economic Area (EEA). For example,

In the event that we need to communicate with our delegations outside the EEA;
To communicate with you or our suppliers when they are outside the EU;
When there is an international dimension to the products/services we provide to you.

International data transfers are subject to special rules governed by the principles of data protection law. This means that we may only transfer your data to countries or international organisations outside the Eu when:

The recipient country is considered by the competent authorities to be safe in terms of the level of protection it applies to personal data.
All appropriate measures have been taken to ensure the safeguarding of security and the proper exercise of your legal rights and the possibility to lodge complaints.
There is an applicable exception under data protection law.

How long will we keep your personal data?

Your data will be kept for the duration of your business relationship with us or for as long as you exercise your right to erasure, opposition or restriction of processing. However, we will retain certain personal identification and traffic data for a maximum period of 2 years in the event that we are required to do so by a Courts or Tribunals or to initiate internal actions arising from improper use of the website.

We would also like to inform you that our information retention policies comply with the time limits set by the different legal responsibilities for the purposes of prescription:

– As a general rule:
Pursuant to the provisions of article 30 of the Commercial Code, and except for other criteria, all company documents and/or information shall be kept for 6 years. This applies to all accounting, tax, labour or commercial documentation of the user.
– Specific deadlines:
Our company must also set minimum deadlines depending on the type of data involved and taking into account the different limitation periods that each of the departments must be aware of.
The table below lists the limitation periods that affect or may affect our organisation:

Subject

Prescription

Regulation

Labour, for the purpose infringements

3 years

Art. 4.2 RD 5/2000

Social Security, for the purpose of infringements

4 years

Art. 4.2 RD 5/2000

Prevention of Occupational Risks, for the purpose of infringements

5 years

Art. 4.3 RD 5/2000

Fiscal, for the purpose of tax debts

4 years

Art. 66 Law 58/2003

Fiscal, for the purposes of checks on compensated contributions or deductions applied

10 years

Art. 66 bis Law 58/2003

Accounting and commercial law

6 years

Art. 30 of the CC

Offences against the Public Treasury and Social Security

10 years

Art. 131 LO 10/1995

Our communications

Any personal information you provide to us will be incorporated into our information systems. If you accept this privacy policy, it means that you give LIBERTY GLOBAL SOLUTIONS the express consent to perform the following activities and/or actions, unless you tell us otherwise

To send you commercial, promotional and direct marketing communications by any means of communication enabled, to inform you of the activities, services, promotions advertising, news, offers and other information about services and products related to us and our group.
To the sending of communications by electronic means, provided that you have subscribed to our NEWSLETTER and have not unsubscribed.
The retention of data for the periods provided in the applicable provisions.

How to stop receiving marketing communications?

You may revoke any express consent you have given us to send you marketing information at any time. To do so, you can unsubscribe by using the opt-out option when it is enabled on our app/website, or by sending us an email with the subject “unsubscribe” to privacy@libertyglobalsolutions.com.

In accordance with the LSSICE (Information Society and E-Commerce Services Law), we never carry out SPAM, therefore, we will not send you unsolicited commercial mailings if they have not been requested or authorised by you. However, in all our communications, you will have the possibility to revoke your consent.
We will not process your personal data for any other purpose than those described above except as required by law or court order.

User responsibility - Truthfulness statement

By providing us with your personal information through electronic channels, you declare that you are over 18 years of age and that all information provided to LIBERTY GLOBAL SOLUTIONS is true, accurate, complete and up to date. To this end, the user confirms that he/she is responsible for the veracity of the data provided and that he/she will keep this information updated so that it corresponds to his/her real situation, being responsible for any false or inaccurate data that he/she may provide, as well as for any damages, direct or indirect, that may arise.

If you send us your CV

In the event that you wish to send us your CV via our email, we inform you that the data provided will be processed in order to include you in the selection processes that may take place, carrying out an analysis of your professional profile with the aim of selecting the most suitable application for the possible vacancy.

We do not accept CV’s sent through other channels (e.g. hand delivered on paper). In the event of any changes to the data, please inform us in writing as soon as possible in order to keep your data up to date. CVs will be kept for a maximum period of one year.
After this period, they will be securely destroyed and all data will be deleted. We guarantee total respect for confidentiality. In this sense, after the aforementioned period, if you wish to continue participating in possible selection processes, you must submit your curriculum vitae again.

The data may be processed and/or communicated to the companies in our group for as long as your CV is kept and for the same purposes as described above.

How do we keep your information secure?

We take the protection of your data very seriously. For this reason, we ensure that appropriate physical, organisational and technological security measures, control and procedures are in place to prevent your information from accidental loss, misuse or malicious access.

We limit access to your data to authorised persons and entities and we ensure that all our staff are properly trained. All those involved in the processing of your personal data are subject to a duty of confidentiality.

In addition, we implement technical procedures to react to any suspected data security breach. If necessary, we will notify you and the competent supervisory authority, in accordance with the regulations in force.

How to exercise your ARCOLP rights (Access, Rectification, Cancellation and Opposition Law)?

Both the RGPD and the transposition norm to Spanish Law (the LOPDGDD), guarantees the exercise of the following rights. You can exercise them at any time and always free of charge:

Right of access

The right to receive a copy of your personal information

Right of rectification

The right to request the correction of errors in personal information.

Right to erasure/deletion (right to be forgotten)

The right to request that we delete your personal information – in some cases, this may include your personal information.

Right of restriction

The right to request restriction of the processing of your data

The right to object to:

The right to object to:
– The processing of your data for direct marketing (including profiling)
– In certain circumstances to our further processing of your data. For example, processing carried out on the basis of our legitimate interest.

Right of portability

The right to receive your personal information in a structured form, in a readable format and/or to transmit this data to a third party – in specific situations.

Automated individual decisions

The right not to be subject to a decision based solely on automated processing, including the creation of profiles, which produces legal effects or significantly affects you.

To exercise any of the above rights, you can write to us with your request to the e-mail address specifically provided for this purpose: privacy@libertyglobalsolutions.com.

You can also contact our Data Protection Officer, AURIS CONSULTORIA LEGAL TRIBUTARIA SLP, directly at the following address:
xavi@aurisadvocats.com
You must enclose with your request information on exactly what you need and, in any case, legally valid proof of your identity.

The supervisory authority in data protection matters

We look forward to resolving any issues or concerns you may have about your personal information. But if you wish to lodge a complaint with the competent authority, you are entitled to do so.
In Cyprus, the highest data protection authority is the Office of the Commissioner for Personal Data Protection (CPDP).
https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_en/home_en?opendocument – Tel: +357 22818456.

Changes to this Privacy Policy

LIBERTY GLOBAL SOLUTIONS LTD reserves the right to modify this policy to adapt it to new legislation or case law.

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