1. Identification Details
You are visiting the website www.smartvel.com owned by CONTENT TRIP SOLUTIONS SL, with registered address at C/ ANTONIO MAURA 10, FLOOR 4 (ZIP 28014) MADRID, with Tax Identification Number (N.I.F.) B86591229, registered in the Commercial Register of Madrid, Volume 30503, Folio 191, Section 8, Sheet M 548952, hereinafter referred to as the “OWNER.”
You can contact the Owner through any of the following means:
Contact email: email@example.com
Through this document, we inform you of the terms and conditions that regulate the access and use of the websites and mobile app applications owned by the Owner, as well as the services and content associated with said websites and applications (hereinafter also referred to as the “site(s)” or the “website(s) and mobile app(s)”).
Accessing or using any website and/or app of the Owner implies that the interested party acquires the status of “user” and, with such status, a series of rights and obligations.
It is your responsibility to access the legal conditions contained on this website and read them carefully, as well as the privacy policies, cookies, or, where applicable, sales conditions. We recommend:
(i) Visiting them each time you intend to access or use the services and content of the site, and
(ii) Printing or storing a copy on your system.
3. Use of the Site
This website provides access to a multitude of information, services, programs, or data (hereinafter referred to as the “content”) on the Internet owned by the Owner or its licensors, which the User may have access to.
The User assumes responsibility for the use of the website. This responsibility extends to any registration that may be necessary to access certain services or content. In such registration, the User will be responsible for providing truthful and lawful information. As a result of this registration, the User may be provided with a password for which they will be responsible, committing to use it diligently and confidentially.
The User undertakes to make appropriate use of the content and services (e.g., chat services, discussion forums, or news groups) that the Owner offers through its website, and, in an illustrative but not exhaustive manner, agrees not to use them to:
• Engage in unlawful, illegal, or contrary to good faith and public order activities.
• Disseminate content or propaganda that is racist, xenophobic, illegal pornography, or that promotes terrorism or violates human rights.
• Cause damage to the physical and logical systems of the Owner, its providers, or third parties, introduce or spread computer viruses or any other physical or logical systems that are capable of causing the aforementioned damages.
• Attempt to access and, where applicable, use the email accounts of other users and modify or manipulate their messages.
• Use the website or the information contained therein for commercial, political, advertising purposes, or for any commercial use, especially in the sending of unsolicited emails.
The Owner reserves the right to remove any comments and contributions that violate respect for human dignity, are discriminatory, xenophobic, racist, pornographic, that harm youth or childhood, public order, or public safety, or that, in its opinion, are not suitable for publication. In any case, the Owner will not be responsible for the opinions expressed by users through forums, chats, or other participation tools.
4. Data Protection
5. Contents Intellectual and Industrial Property
The Owner is the owner of all intellectual and industrial property rights of its website, as well as the elements contained therein (including but not limited to: images, photographs, sound, audio, video, software, or texts; trademarks or logos, color combinations, structure and design, selection of materials used, computer programs necessary for its operation, access, and use, etc.), owned by the Owner or its licensors.
All rights reserved. In accordance with the provisions of articles 8 and 32.1, second paragraph, of the Intellectual Property Law of Spain, the reproduction, distribution, and public communication, including the modality of making available, of all or part of the contents of this website, for commercial purposes, on any medium and by any technical means, without the authorization of the Owner, are expressly prohibited.
6. Exclusion of Guarantees and Liability
El Usuario reconoce que la utilización de la página web y de sus contenidos y servicios se desarrolla bajo su exclusiva responsabilidad. En concreto, a título meramente enunciativo, el Titular no asume ninguna responsabilidad en los siguientes ámbitos:
The User acknowledges that the use of the website and its contents and services is carried out under their sole responsibility. Specifically, and for illustrative purposes only, the Owner assumes no responsibility in the following areas:
• The availability, functioning, quality, or interoperability of the website, its services, and contents.
• The suitability of the website for the User’s objectives.
• The User’s or third parties’ infringement of applicable legislation, particularly regarding intellectual and industrial property rights owned by other individuals or entities.
• The existence of malicious codes or any other harmful computer element that may cause damage to the User’s or third parties’ computer systems. It is the User’s responsibility to have appropriate tools for the detection and disinfection of such elements.
• Unauthorized third-party access to contents or services, or the capture, deletion, alteration, modification, or manipulation of messages and communications of any kind that such third parties may carry out.
• Damages to computer equipment during access to the website and damages to Users resulting from failures or disconnections in telecommunications networks that interrupt the service.
• Damages or losses arising from events beyond the control of the Owner or force majeure.
In the event of the existence of message boards or similar spaces, it should be noted that the messages reflect solely the opinion of the User who sends them and that the User is solely responsible for their content. The Owner is not responsible for the content of messages sent by the User.
7. Modification and duration of this Legal Notice
The Owner reserves the right to make, without prior notice, any modifications it deems appropriate to its website, including changing, deleting, or adding any content and services provided through it, as well as the way in which they are presented or located on the portal.
The validity of these conditions will be determined by their publication and will remain in effect until they are modified by duly published ones.
In the event that www.smartvel.com includes links or hyperlinks to other websites, the Owner will not exercise any control over such sites and content. Under no circumstances will the Owner assume any responsibility for the content of any link belonging to a third-party website, nor will it guarantee the technical availability, quality, reliability, accuracy, scope, truthfulness, validity, or constitutionality of any material or information contained in any of these hyperlinks and other websites. Likewise, the inclusion of these external connections does not imply any kind of association, merger, or participation with the connected entities.
9. Exclusionary Rights
The Owner reserves the right to deny or withdraw access to the site and/or the services offered, without prior notice, at its own or a third party’s request, to users who fail to comply with the content of this legal notice.
The Owner will pursue the breach of these conditions, as well as any misuse of its website, by exercising all civil and criminal actions that may correspond to it under the law.
11. Applicable Law and Jurisdiction
The relationship between the Owner and the User will be governed by the current Spanish legislation. Any disputes or claims arising from this legal notice will be resolved by the Spanish courts and tribunals with jurisdiction over consumer and user endeavors.
This website is intended for users of legal age. Individuals under the legal age are not authorized to use our services and should not provide us with their personal data. Please note that if such circumstances occur, the Owner will not be responsible for any consequences resulting from non-compliance with the notice stated in this clause.
13. Security Measures – SSL
The Owner has obtained an SSL certificate (“Secure Sockets Layer”) for its website.
An SSL certificate allows for the protection of all personal and confidential information that may be handled on a website, regardless of the information being transmitted. This includes, for example, information sent from any contact forms on the website to the server, or data entered for newsletter subscriptions or access to protected areas, etc.
The website address will appear in green, activating the “https” protocol that enables secure connections from a web server to the user’s browser.
The purpose of this policy is to inform individuals about the different data processing activities carried out by this organization through the website that may affect their personal data in accordance with the provisions of Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights, and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016.
1. Identification and contact details of the data controller
The organization CONTENT TRIP SOLUTIONS SL, with registered address at C/ ANTONIO MAURA 10, FLOOR 4 (28014 MADRID) MADRID, with Tax Identification Number (N.I.F.) B86591229, contact phone: 917558540, and email firstname.lastname@example.org.
2. Purposes of the processing of your personal data
Users/visitors of the data controller’s website
We will process the personal data provided through our web forms for the following purposes:
• Addressing requests, complaints, and incidents communicated through our contact channels integrated on the website.
• Understanding the user’s behavior on the website in order to detect possible cyber attacks on our website.
• Compliance with the applicable legal obligations that directly regulate our activity.
• To protect and exercise our rights or respond to claims of any kind.
• If applicable, sending commercial communications related to the goods or services that constitute our activity, and/or news or newsletters related to our sector.
3. Legal basis for data processing
Users/visitors of the data controller’s website
• Consent given by you for the processing of your data for the mentioned purposes. The refusal to provide your personal data will make it impossible to process your data for the mentioned purposes.
• Compliance with the legal obligations that apply to us. In this case, the data subject cannot refuse the processing of personal data.
• Our legitimate interest in protecting our image, business, and reputation by preventing attacks on our website. In this case, the data subject cannot refuse the processing of personal data, although they may exercise, if applicable, the rights recognized in the eighth section of this policy.
4. Data retention periods & criteria
The personal data provided will be kept for as long as necessary to fulfill the purposes for which they were initially collected. Once the data is no longer necessary for the specific processing, it will be securely blocked and, if applicable, made available to competent Public Administrations and Bodies, Courts and Tribunals, or the Public Prosecutor’s Office, during the statutory limitation periods for any actions that may arise from the relationship with the client and/or the legally established retention periods.
5. Automated decisions and profiling
The website does not make automated decisions or carry out profiling activities.
During the period of personal data processing, the organization may disclose your data to the following recipients:
• Courts and Tribunals.
• State Security Forces and Bodies.
• Other competent public authorities or bodies, when the data controller is legally obliged to provide personal data.
7. International data transfers
The organization does not perform any International Data Transfer.
Interested parties have the right to exercise, at any time and free of charge, their rights of access, rectification, erasure, and restriction of processing, as well as to object to the processing, request the portability of their data (where technically feasible), or withdraw their consent. They also have the right not to be subject to a decision based solely on automated processing, including profiling.
To exercise these rights, individuals may use the forms provided by the organization or send a written request to the postal address or email address provided above. However, they may be asked to provide their ID card or any equivalent document to verify their identity if it cannot be verified by other less intrusive means.
If individuals believe that their rights regarding the protection of their personal data have been violated, especially if they have not obtained satisfaction when exercising their rights, they have the right to lodge a complaint with the competent Data Protection Authority (Spanish Data Protection Agency) through its website: www.agpd.es.
In compliance with Article 21 of Law 34/2002 on Information Society Services and Electronic Commerce, if individuals do not wish to receive further information about our services, they can unsubscribe by sending an email to the address email@example.com, with the subject line “UNSUBSCRIBE.”
9. Data accuracy
The data subject guarantees that the provided data is true, accurate, complete, and up to date. They undertake to inform the organization of any changes to the provided data through the channels specified in section one of this policy. The data subject will be responsible for any direct or indirect damage or loss that may be caused as a result of non-compliance with this obligation.
In the event that the user provides third-party data, they declare that they have the consent of the individuals concerned and undertake to provide them with the information contained in this clause, releasing the organization from any liability arising from non-compliance with this obligation.
10. Social Media
Social media platforms are part of the daily lives of many Internet users, and the Organization has created various profiles on some of these platforms.
All users who visit our website have the opportunity to join our social media networks or groups.
11. Modifications / Updates
If you have any questions about this policy, you can contact CONTENT TRIP SOLUTIONS SL through the following email address: firstname.lastname@example.org
For what purposes is your information used and who uses it?
This Website uses third-party cookies to personalize content and ads, provide social media features, analyze traffic, generate statistical information, and analyze your browsing habits. This allows us to personalize the content we offer and show you advertising related to your preferences. Additionally, we share information with our partners in social media, advertising, and web analytics, who may use the collected information and combine it with other information provided by you. Please note that these third parties may have their own cookies.
(a) Facilitates user navigation on the Website;
(b) Allows users to access the various services offered on the Website;
(c) Saves users from having to reconfigure general predefined features each time they access the Website;
(d) Improves the functioning and services provided through the Website by analyzing the information obtained from the installed cookies;
(e) Enables a Website, among other things, to store and retrieve information about a user’s browsing habits or their device, and depending on the information they contain and how the device is used, they can be used to recognize the user.
Most browsers accept cookies as default and, regardless of them, allow or block temporary or stored cookies in the security settings.
Please note that in order to use and have a better browsing experience, it is necessary to have cookies enabled, especially technical cookies that are necessary to identify you as a registered user each time you access this website.
If you do not want to receive cookies, please configure your internet browser to delete them from your computer’s hard drive, block them, or notify you if they are being installed.
2. What type of cookies does this website use?
Third-Party Cookies: These are cookies sent to the user’s terminal equipment from a device or domain managed by the website’s editor and from which the requested service is provided.
Below is the list of cookies we use:
Google Analytic Cookies: _ga, _gat, _gid
• Type: Analytical cookies
• Purpose: These cookies are used to analyze the user’s browsing experience and allow us to improve our website to meet their needs. They typically remain in the user’s browser until the cookies are cleared or the defined time for deletion has passed.
• More information: https://support.google.com/analytics/answer/6004245?hl=en
• Duration: _ga: 2 years; _gat: session duration; _gid: 1 day.
Hubspot Cookies: __hstc, hubspotutk, __hssc, __hssrc
• Type: Analytical cookies
• Purpose: These cookies track a visitor’s identity, their sessions, and determine if they have restarted their browser.
• More information: https://knowledge.hubspot.com/es/account/hubspot-cookie-security-and-privacy
• Duration: __hstc: 6 months; hubspotutk: 6 months; __hssc: 30 minutes; __hssrc: session duration.
4. Data retention periods or criteria
The personal data provided will be retained for as long as necessary to fulfill the purposes for which they were initially collected.
Once the data is no longer necessary for the relevant processing, it will be properly blocked and, if necessary, made available to the competent Public Administrations and Authorities, Courts, or the Public Prosecutor’s Office, for the duration of the statutory limitation periods for any actions that may arise from the relationship maintained with the customer and/or the legally prescribed retention periods.
5. How to block, revoke, or delete installed cookies
You can allow, block, revoke, or delete cookies installed on your device by configuring your browser options. You can find information on how to do this for the most common browsers in the following links:
Microsoft Edge: https://privacy.microsoft.com/es-es/windows-10-microsoft-edge-and-privacy
However, please note that disabling some cookies may prevent or hinder navigation or the provision of services offered on the website.
To revoke initially accepted cookies, you must click on the “revoke cookies” button.
6. Recipients of the information
The companies listed in the Configuration Panel will have access to the information obtained through the website’s cookies. In the Configuration Panel, you can also see the purposes for which they use the information and their respective privacy policies.
We also inform you that some of our providers and collaborating companies may transfer data to third countries. You can find information about transfers to third countries that they may make in their respective privacy policies, accessible through the links provided in the Configuration Panel.
7. Modifications / Updates
Information security policy
CONTENT TRIP SOLUTIONS SL (hereinafter referred to as SMARTVEL) has safeguarding the Security of Information, whether personal or not, as one of its objectives. To achieve this, SMARTVEL establishes an Information Security system with the aim of ensuring the reduction of associated risks and cybersecurity, ensuring that information is accessible only to those users who have a legitimate need to perform their functions, that it is protected, available, and used for the purposes for which it was obtained. To achieve this, SMARTVEL defines the following strategic objectives:
● Minimize the risks of loss of confidentiality, integrity, and availability of information received, generated, processed, and stored by SMARTVEL.
● Support the areas of the company in securing the information assets that support business operations and information with personal data.
● Raise awareness among employees regarding information security in the execution of their functions.
● Maintain an Information Security and Cybersecurity program that supports the organization’s strategic objectives and new business projects.
● Compliance with legal requirements, commitments made to clients and suppliers, and any regulations, internal rules, or guidelines to which the company is subject.
● Continuously improve the Information Security system.
● Promote awareness and training in information security.
● Ensure the ability to respond to emergency situations, restoring the operation of critical services as quickly as possible.
The Information Security Policy concerns all users and must be applied to all information created, processed, or used by SMARTVEL, regardless of the medium, format, presentation, or location. All security measures adopted are aimed at protecting the information and the information systems that support it, including applications, operating system resources, telecommunications networks and media, and computer equipment, whether managed by SMARTVEL or by those companies or individuals expressly authorized for this purpose, such as those who have entered into a service provision or data processing agreement with SMARTVEL or legally authorized assignees. The Information Security and Cybersecurity Policy is focused on trying to ensure the following three main scenarios:
● Compliance with confidentiality, which involves ensuring that critical, sensitive, private, or personal information managed by the organization is not stolen or accessed by unauthorized individuals.
● Minimizing disruptions to availability, where the services provided by the organization become inaccessible or unusable.
● Ensuring the integrity of information systems, preventing data or system corruption within the organization that could impact the accuracy or integrity of information and processing, and also potentially affect service availability.
The Information Security Policy will be implemented through security regulations that address specific aspects and will be reviewed at least once a year and whenever there are significant changes within the organization, in order to ensure that it aligns with the organization’s strategy and needs. This policy applies to all SMARTVEL workplaces and is implemented within the framework of Information Security according to the ISO 27001:2013 standard. Ed1. RE02/PC05 – 18/05/2022.
Download the Information Security Policy here.