Privacy policy


Compliance with the General Data Protection Regulation (RGPD)

IMPORTANT NOTICE: The translated versions of the contracts and legal policies are provided solely as a convenience to facilitate reading and understanding of the Spanish versions. The objective of providing translations of contracts and legal policies is not to create a legally binding contract, and not be a substitute for the legal validity of the Spanish versions. In the event of any dispute or conflict, the Spanish versions of the contracts and legal policies will under all circumstance govern our relationship and prevail over the terms in any other language.

  • Responsable party: AVEMUNDE DESARROLLOS A MEDIDA, S.L.
  • Purpose: Manage full access to Services, communications, commercial or otherwise, and updates thereof.
  • Legitimation: Consent of the interested party.
  • Target: There is no transfer of data, except for National Authority or Entity.
  • Rights: To access, rectify and delete data, as well as other rights, as explained in the additional information

In accordance with Organic Law 15/1999, of December 13th, regarding the Protection of Personal Data (LOPD), and Regulation (EU) 2016/679, of the European Parliament and of the Council, of April 27th ("General Data Protection Regulations" or "GDPR"), this Privacy Policy applies to the processing of personal data undertaken by AVEMUNDE DESARROLLOS A MEDIDA, S.L. - hereinafter Avemunde- as responsible party in relation to the data that users and / or customers (physical individuals) provide as a result of contracting any of the services provided by Avemunde, (hereinafter, the "Services"), or gathered from any of the sections of the website www.tworoles.com.

If you do not agree with the terms of this Policy, do not access or use the Services. This Privacy Policy is not applicable to any other third party product, service or activity.


Party responsible for handling your data

  • Registered name: AVEMUNDE DESARROLLOS A MEDIDA, S.L.
  • Commercial brand: Avemunde
  • Address: Calle Cortes de Aragón Nº 64 3º G
  • NIF: B99454985.
  • Email: info@avemunde.es.
  • Inscription details: Inscribed into the Commercial Register of Zaragoza, Spain Tomo 4142, Libro 0, Folio 121, Sección 8, Hoja Z 59245.
  • Data Protection Officer (DPO): To contact Avemunde's Data Protection Officer, please write to the following address: info@avemunde.es

Our Privacy Policy explains how Tworoles collects, uses and shares information when a user uses our service. If you use our service, you authorize the use of the data required by this explanation text.

The Privacy Policy may be updated in the future to reflect any changes.

If you have any questions related with this Privacy Policy, you can contact us at contact@tworoles.com.


Purpose of data handling

Your personal data will be used for the generic purpose of managing and monitoring the established contractual or business relationship and, specifically for:

  • The purpose of the treatment is to manage the complete access and the correct use of the Services by the users of the same and to communicate with the users in response to incidents, requests, comments and questions that they make us through of services or contact forms on the website (including, chats or phone calls).
  • To provide, update, maintain and protect the Services, Websites and activities.
  • To offer new products, services, special offers or updates.
  • Communications: We may send you emails, messages and other types of communications in relation to Services, technical issues and any modifications thereof. These communications are considered part of the Services and cannot be waived.
  • Commercial Communications (Marketing): We may use your data to contact you, both electronically and non-electronically, to conduct surveys, obtain your opinion on the service provided, and, occasionally, to notify you about changes, important service developments, special offers and / or promotions of our services or of third party companies related to us. These commercial offers will, in any case, be expressly and separately authorized by the user who can at any time revoke their consent to receiving these notifications by using the mechanism implemented for such a purpose, or from client account settings/preferences.

We will not handle your personal data for any other purpose beyond that described above unless required to do so by law or court order.

Data preservation term: The personal data provided will be kept and handled while maintaining a business relationship for the provision of services, without prejudice to the possibility of exercising your right of withdrawal, in which case Avemunde will block your data during the time that such legal obligations persist.

The personal data of those interested in receiving information about the Services will remain in the system indefinitely, provided the interested party does not request their deletion.


Information collected and use of information

Tworoles collects personal information requested in the registration. If you use a third-party service connection, such as Facebook, you can be requested for specific additional information. Once registered, the messages sent through the service are temporarily or indefinitely stored, as well as the information provided in the User Profile.

User connections enable us to collect non-personal information. This information can be exploited by third party testing services like Google Analytics. These services collect information sent by the web browser used: device, resolution, IP address, operating system, etc. In addition, we store certain information from the browser using "cookies". A cookie is a small text file containing a string of alphanumeric characters that identifies your browser. If you do not want us to collect cookies, you can set your browser to not allow to stored them. However, you should consider that cookies may be necessary for the proper performance of the website.

We may use the email provided in the registration to contact you. You can receive notifications alerting you of different situations. For example, when a user sends you a message or a conversation that you requested has been confirmed. You can also receive newsletters. The reception of these messages is configurable from the service.


Information sharing

You can choose the public who can see your user profile and the information that is in it. You can choose whether you want the information public, limited to Tworoles users, friends, etc. In addition, you always have the possibility to remove all your personal information.


Legitimation of data handling

The legal basis for data handling is legitimation based on the consent given by the interested party for the purposes described above, which will be requested at the time of:

  • prior to proceeding with the handling of your data,
  • proceeding to register as user or,
  • proceeding to activate Tworoles Services

The requests for information that you send us require that the interested party voluntarily provides us with the necessary information that will enable us to assist you or provide you with the Services. The obligatory nature or the need to provide us with this data will be marked with an asterisk (*) on the forms or sections corresponding to each service.

However, the interested party may freely refuse to provide us with this data or, subsequently, revoke any consent previously granted to process your data, although this refusal will prevent us from being able to respond to your request or provide the service in question.

Likewise, we can handle your data based on the legitimate interest of Avemunde in maintaining and retaining its customers and / or users and thereby better meet their expectations or previously expressed interests, eg improve services and products, manage requests, queries or claims, offer products and services similar to those contracted, inform about promotions, etc., without prejudice to Avemunde's compliance with the remainder of its obligations in relation to sending commercial communications electronically.

Avemunde understands that by providing us with this data, the interested party guarantees and is responsible for the veracity, timeliness and accuracy thereof and that they expressly accept and consent to its handling for the purposes described above.


Recipients of cessions or transfers

In general, Avemunde will not transfer your personal data to third parties unless we are legally bound to do so or you have expressly authorized us to do so when making use of our services.


Rights of interested parties

Anyone has the right to obtain confirmation on whether or not Avemunde is handling their personal data. In particular, you can exercise the following rights in relation to Avemunde:

  • Right of access: allows the interested party to know and obtain information about their personal data submitted for handling.
  • Right of rectification: it allows for the correction of errors, modifying data that may be inaccurate or incomplete and thereby guarantee the accuracy of the information object of the data handling.
  • Right to delete: it allows users to request the elimination of the data being handled, when it is no longer necessary for the execution or provision of any given service.
  • Right to opposition: the right of the interested party to oppose the processing of their personal data or to request cessation of same, except for legitimate reasons or for the exercise or defence of potential claims, in which case we will keep the data blocked during the corresponding period while the legal obligations persist.
  • Right to oppose the sending of advertising: Those interested may oppose the sending of commercial communications by Avemunde. In this case, you may revoke your consent at any time to receiving these notifications using the mechanism implemented for that purpose, or from the client account settings/preferences.
  • Limiting the data handling: In certain circumstances, the interested parties may request the limitation of the processing of their data, in which case they will only be kept for the exercise or defence of claims or legal suits.
  • Data portability: interested parties may ask to receive the data relating to them and that has been facilitated to us or - always providing it is technically possible to do so -- they may request that we send the data to another data handling party of their choice, in a structured format of common use and mechanical reading.
  • The right not to be subject to automated individual decisions (including the preparation of profiles): the right not to be the subject of any decision based on automated processing that produces any substantial effect.
  • Opportunity to withdraw consent: Likewise, the interested party has the right to withdraw the consent given at any time, without affecting the legality of the data handling based on the consent given at the time of providing us with their data.

If you wish to exercise any of the rights detailed above, please write to us with all your information, including ID to: AVEMUNDE DESARROLLOS A MEDIDA, S.L. Calle Cortes de Aragón Nº 64 3º G, Zaragoza (Spain), or send us an e-mail to info@avemunde.es indicating the type of right you wish to exercise.

Opportunity to make a complaint before the Supervisory Authority: Avemunde also informs you of your right to file a complaint with the Spanish Agency for Data Protection (www.agpd.es) if you consider that the data handling does not comply with current regulations.


Policy regarding minors

Tworoles has not been developed for use by children under 16 years of age. If your child has given us personal information without your consent, you can contact us at contact@tworoles.com. We do not knowingly collect personal information from children under the age of 16, so if we learn that a child under the age of 16 has provided us with personal information, we delete all user account information.


About children

Tworoles was not developed to be used by persons under 16 years old. If your child has provided us personal information without your allowance, you can contact us at contact@tworoles.com. We do not collect personal information from children under 16 years old consciously, so if we have knowledge that a child under 16 has provided us personal information, we delete all account information.


Links

The Service may contain links to other websites which we are not responsible for the privacy practices they have. Therefore, all users must read the privacy statements of Web sites they visit, because they may collect personal information.


Version and validity of this document

This document was originally written in Spanish (Spain). If any translated version of this document conflicts with the version in Spanish, the Spanish version rules.

Last revised May 24, 2018.