1. WHO ARE WE? We are Aitaca Remote Tech S.L. domiciled in Madrid, with NIF B-67777011, registered in the Mercantile Registry of Madrid, Volume 42738, Folio 23, inscription 1 with page M-755762 (hereinafter Aitaca) and we treat your personal data as data controllers. This means that we are in charge of how we use and protect your data. Read more.
2. WHAT DATA DO WE WORK WITH? In order to give you a good service, we need, for some functionalities, certain personal and anthropometric data. Read more.
3. WHAT DO WE USE YOUR DATA FOR? We will use your data, among other purposes, to provide you with our services. See
   more.
4. WITH WHOM DO WE SHARE YOUR DATA? We will share your information with service providers who help or support us. Read more.
5. YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In some cases, you also have other rights, for example, to object to our use or transfer of your data, as explained in detail below. Read more.

BEFORE WE START…

• In this Privacy Policy you will find all the relevant information that applies to the use we make of personal data to the use we make of our users ‘ personal data, regardless of the channel or medium (online or in person) you use to interact with us.
• This Privacy Policy may be updated from time to time, so we recommend you to read it again if you use our services should you use our services again.
• In addition, this Privacy Policy is also intended to explain this Privacy Policy is also intended to explain what rights you have as a user and how to exercise them.
• We are transparent about what we do with your personal data, so that you understand the implications of the uses we make of your personal or the rights you have in relation to your data:
  • We make permanently available to you all the information in this Privacy Policy , which you may consult whenever you wish. Privacy Policy that you can consult whenever you consider it appropriate and in addition,
  • you will also find information about of each treatment from your data personal data as you interact with us.
• Some names we will use in this Privacy Policy:
  • • When we talk about our Platform, we will refer in general to any of the digital or in-person channels or means digital or in-person channels or media you have used to interact with us.

• Aitaca is responsible for the personal data collected through the Platform. The Platform is owned by Aitaca. You can find all our contact information in the footer of the website.
• We are committed to protecting your privacy online and we want to assure you that we will use your assure you that we will use your data in a transparent and secure manner. In accordance with the provisions of the applicable data protection legislation, in particular, Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), Aitaca, undertakes to comply with the legislation in force on the protection of personal protection of personal data and to adopt the appropriate legal, technical and organizational technical and organizational measures to prevent damage or loss of our customers’ personal loss of our customers ‘ personal data.

2. WHAT DATA DO WE WORK WITH?

Depending on the products, depending on the products, services or functionalities that you want to enjoy at we will need to treat some data or others, which in general will be, depending on the case, the following:

• • • data multimedia: Photographs or screenshots you provide to use our virtual sizing services, such as ring size prediction or other personalized fitting or recommendation services. These images are processed anonymously and securely.
    • derived anthropometricdata: Information calculated from the images you provide us, such as anthropometric measurements or other data related to physical characteristics. This data is used exclusively to provide you with a recommendation or a personalized or personalized adjustment and are stored anonymously in our cloud.
    • usage and analytics data: Information about how you interact with our services, which we collect using analytics tools, such as PostHog, to improve the user experience and optimize our services: events, in-app behavior, interactions and performance data. The data collected may include information about your device, location and usage of our platform. In no case is data about the users recorded.

It is important to note that none of the data that we work with contain information that would directly identify an individual.

3. FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data for the sole purpose of providing you with personalized and accurate services, as well as to continuously improve the quality of our services. In particular, we use your data to:

• • Service Provision: When you use our size recommendation service, you provide us with an image. This image is processed by advanced algorithms to suggest a size for you. This process is done anonymously.
  • Improved User Experience: The data collected through our analytics tool is used to improve the functionality of our service. is used to improve the functionality of our service, optimize the user experience, detect and correct errors, and perform statistical and behavioral analysis.

4. HOW LONG WILL WE KEEP YOUR DATA?

The period of conservation of your data will be the minimum necessary to meet the request and future needs as explained below:

Conservation Exceptions: In some cases, our customers (business partners) may request data retention for a different period, either longer or shorter, depending on their specific business or regulatory needs. When these special retention periods are agreed, we ensure that any extension or shortening of the time period complies with all applicable data protection applicable data protection regulations and that the user’ s rights of the user are respected at all times.

In all cases, our aim is to ensure that data is retained only for as long as is strictly necessary and is securely deleted when no longer required. strictly necessary and is securely deleted when no longer required. Regardless of the fact that we process your data for the time strictly necessary to fulfill strictly necessary to fulfill the corresponding purpose, we will subsequently keep them duly stored and protected for as long as liabilities arising from time in which liabilities arising from the processing may arise, in compliance with the regulations in force at any given time. Once the possible actions in each case are prescribed, we will proceed to the deletion of personal data.

If you have agreed to be part of a group of ” test users”, we will process your data until you unsubscribe or or cancel your ” test users” status.

5. WILL WE SHARE YOUR DATA WITH THIRD PARTIES?

Aitaca will not transfer the personal data of the Users to any third party without third party without a legal basis that legitimizes such treatment. This means that we will not share your personal data with third parties except:

1. 1. When we are legally obliged to do so, we may communicate your data to the authorities and entities that require us to do so.
   2. The correct provision of the services requested by the User. Will be able to have access to your personal data the Aitaca ‘ s data processors, that is to say, service providers who have to access your personal data in order to carry out the personal data in order to perform the functions for which they were hired.

In addition, we would like to inform you that these service providers We would also like to inform you that with these service providers we sign that cover all appropriate security measures to ensure the protection of your personal data. appropriate security measures to ensure the protection of your data in accordance with the in accordance with the applicable data protection regulations. Our data processor is Amazon Web Services (Amazon.com, Inc.), which is a U.S. company under the Privacy Shield adequacy decision the Privacy Shield adequacy decision, so that the processing of all the data it manages is adequate is adequate and in accordance with the guidelines of the RGPD. You can access their privacy policies at https://aws.amazon.com/privacy/

All data we process is stored and processed on Amazon Web Services processed on Amazon Web Services (AWS) servers located in Ireland. This means that your data remains within the European Economic Area (EEA), ensuring that it is subject to the stringent data protection regulations of the data protection regulations of the European Union, including the General Data Protection Regulation ( GDPR). We do not conduct international data transfers outside the EEA.

6. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

We undertake to respect the confidentiality of your personal data and to guarantee you the your personal data and to guarantee you the exercise of your rights, which you can exercise by sending us an e-mail to the following address : legal@aitaca.io, simply indicating the reason for your request and the right you wish to exercise. In case we consider it necessary to identify you, we may ask you for a copy of a document proving your identity.

We may also offer you the opportunity to exercise your rights and We may also offer you the ability to exercise your rights and configure your your privacy preferences when using some of our services some of our services or by making available to you specific specific channels within our Platform.

In particular, regardless of the purpose or legal basis under which we process your data, you have the right to:

• • Ask us for access to the information we have about you: We remind you that we do not know who you are, since your data is anonymous to us.
  • Ask us to delete your data to the extent that they are no longer necessary for the purpose for which we need to treat them as we have informed you above, or that we no longer have the legitimacy to do so. Remember that we do not know who you are, and that we delete all data automatically as explained in section 4.

If you have provided us with your consent to the processing of your data for any purpose, you also have the right to withdraw your consent at any time. Some of the ways in which you can withdraw your consent are explained in section 3 in which we explain in section 3 where we explain the purposes for which we process your data.

Where we are entitled to process your data on the basis of your consent or for the performance of the contract, you also have the right to request portability of your personal data. This means that you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, so that it can be transmitted to another entity directly, where technically possible.

Finally, we inform you of your right to lodge a complaint with the relevant data protection relevant data protection supervisory authority, in particular, before the Spanish Data Protection Agency
(https://www.agpd.es/portalwebAGPD/index-ides-idphp.php).

Updating Privacy Policy: This privacy policy may be updated from time to time to reflect changes to our services or applicable legal regulations. In the event of significant changes, we will notify users through a conspicuous notice on our platform or other appropriate or by other appropriate means before such changes become effective. We encourage you to review this policy regularly to stay informed about how we are protecting your information.