Privacy Policy

1. Which company is responsible for processing your data?

The company responsible for processing your data is BELEADER INTERNET MARKETING S.L., a Spanish company, with registered office at C/ Alvaro Caballero 14, 2nd Floor, 28023 Aravaca, Madrid, Spain, with Tax ID B85218154, registered in the Madrid Commercial Registry, Volume 24.804, Folio 10, Section 8, Sheet M-446416, Entry 1 (hereinafter, “BELEADER”).

In compliance with Regulation (EU) 2016/679 of April 27, 2016 (GDPR) and Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights (LOPDGDD), this Privacy Policy governs access to and use of the services provided by BELEADER to Internet users (hereinafter, the “User”) interested in the services (the “Services”) and content (the “Content”) hosted on BELEADER’s websites (the “Websites”).

2. Why is BELEADER entitled to process your data?

The data of Users collected through online registration forms available on the Websites are collected by BELEADER for the purpose of providing the Services offered through each Website.

In accordance with applicable privacy regulations, BELEADER, owner of the Websites, informs the User of the existence of an automated file of personal data, duly registered with the General Data Protection Registry of the Spanish Data Protection Agency, created by BELEADER under its responsibility.

3. What are the purposes of processing your personal data by BELEADER?

a. Processing of personal data by BELEADER

Your personal data collected by BELEADER may be used for the following purposes:

i. The provision of the services offered on the Website.
ii. Sending commercial communications to Users by letter, telephone, email, SMS/MMS, instant messaging, or other equivalent means of communication related to BELEADER’s services, provided that the User has consented to this purpose of data processing.

The User also consents to the processing of their data for profiling and data segmentation. Such processing may aim to analyze and produce statistics to understand website traffic and usage by Users, as well as to determine their preferences to send promotional information aligned with their interests.

b. Sending of commercial communications on behalf of third parties

BELEADER may process your personal data, provided you have consented to it, to send, by letter, telephone, email, SMS/MMS, or equivalent means of communication, commercial communications or information from companies related to the following sectors:

• Finance: Loans from financial institutions and insurance.
• Legal: Lawyers, Legal Services, Law Firms.
• Consumer Goods: Food, Fashion and Decoration, Health and Beauty, Textiles, Home, Personal Care, Office Supplies, Automotive, Cleaning Products, Furniture, Optics and Audiology.
• Leisure: Tourism, Publishing, Toys, Collectibles, Sports, Hobbies, Communication, Entertainment, Interior Design, Gardening, Photography, Image and Sound.
• Telecommunications: Telecommunications, Technology and Internet products and services.
• Automotive: Products and services related to cars, motorcycles and trucks.
• NGOs: Products and services related to non-governmental organizations.
• Jewelry and Precious Stones: Products and services related to jewelry, costume jewelry, and gemstones.
• Energy and Water: Products related to electricity, hydrocarbons, gas, and water.
• Education: Products and services related to education, textbooks, school or training materials, and offers for in-person or distance courses.

c. Data transfers to third-party companies

If you have given your free, informed, specific, and unambiguous consent, your data may be shared with companies related to the sectors mentioned in section b).

The purpose of such transfers will be the sending by these companies, via letter, telephone, email, SMS/MMS, instant messaging, or equivalent means of communication, of information and commercial communications that may be of interest to you.

d. Commercial profiling

If you consent, BELEADER may create commercial profiles based on the information you provide (age, gender, declared habits, interests, etc.) and your interaction with our communications, in order to adapt and personalize the advertising content you receive according to your preferences. This processing does not involve automated decisions with legal or significant effects and is based solely on your consent, which you may revoke at any time by emailing [email protected]. You may object to profiling or withdraw your consent without affecting the lawfulness of processing based on prior consent.

e. Anti-fraud
Communicating data to third parties for anti-fraud purposes. This includes verifying data such as name, surname, postal address, email, and age for identity verification, fraud prevention, or compliance with anti–money laundering regulations.

WINR Statement

We may share your personal information with our partner WINR Data Pty Ltd (WINR) and their global partners for the following purposes:

• Fraud Prevention – preventing others from misusing your personal information.
This may involve identity verification for anti-fraud, anti-money laundering, anti-crime, asset recovery, debt collection, and reuniting individuals with unclaimed assets; and

• Digital Advertising – providing personalized advertising and content that is relevant to you.
This may involve identity resolution for data analysis, matching, and linkage.

WINR and their global partners will process and retain your personal information for as long as necessary for these specific purposes and on the lawful bases of legitimate interests and consent, where required.

You can submit a request to exercise any of your privacy rights to the Data Protection Officer at WINR:
https://www.winrdata.com/privacy-policy/

4. Accuracy of data

The User guarantees that the personal data provided are truthful and is responsible for communicating any modification thereof to BELEADER. The User shall be responsible for the accuracy of the data provided, and BELEADER reserves the right to exclude from registered services any User who has provided false data, without prejudice to other legal actions.
It is recommended to exercise maximum diligence in data protection by using security tools, as BELEADER cannot be held responsible for unlawful theft, alteration, or loss of data.

5. Data retention

Personal data provided will be retained by BELEADER as long as the User does not express their desire to unsubscribe from BELEADER’s services, for the purpose of receiving information about company products.

6. User rights regarding their data

The User has the right to (i) access their personal data, (ii) request rectification of inaccurate data, (iii) request deletion, (iv) request restriction of processing, (v) object to processing, (vi) exercise the right to be forgotten, and (vii) request data portability.
To exercise these rights, the User must prove their identity to BELEADER by sending a copy of their National Identity Document or any other legally valid means.
The User may exercise all these rights by emailing [email protected] stating the reason for their request.
The User may also send their request by post to the following address:

Without prejudice to any other administrative or judicial remedy, the User has the right to lodge a complaint with a Supervisory Authority, particularly in the Member State where they have their habitual residence, place of work, or the place of the alleged infringement, if they consider that the processing of their personal data does not comply with regulations, or if their rights are not satisfied.
The Supervisory Authority will inform the complainant of the course and outcome of the complaint.

7. Data security

Protecting the privacy and personal data of its clients and visitors is very important to BELEADER. Therefore, BELEADER takes all possible measures to prevent misuse of your data. Only authorized personnel have access to your information.
BELEADER maintains personal data protection security levels in accordance with applicable regulations and has implemented all available technical means to prevent the loss, misuse, alteration, unauthorized access, and theft of data provided by Users through the Websites, although it is informed that Internet security measures are not infallible.
BELEADER undertakes to maintain the duty of secrecy and confidentiality regarding personal data in accordance with applicable law, as well as to ensure secure processing in any data transfers, including international transfers, that may occur.

8. Questions

If you have any questions about this privacy policy, please contact us by email at bajas [ – at – ] beleader.com.

9. Acceptance and Consent

The User declares to have been informed of the terms regarding personal data protection, accepting and consenting to the automated processing thereof by BELEADER, in the manner and for the purposes indicated in this Privacy Policy.

10. International transfers

At this time, no international transfers of personal data are made to third countries or international organizations. All processing is carried out within the European Economic Area (EEA). If an international transfer is planned in the future, users will be informed in advance and this policy will be updated to indicate:
– recipient countries
– applicable safeguards (adequacy decision, standard contractual clauses, binding corporate rules, or other valid mechanisms)
– effective date of the transfer. Likewise, the AEPD will be notified, if applicable, in accordance with Article 49 of the GDPR.