1. INTRODUCTION

Thank you for using Santa Ponsa Sol! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Santa Ponsa Sol. We have a dedicated privacy team that’s committed to protecting all the personal information we collect and help ensure that personal information is handled properly worldwide.

This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the Santa Ponsa Sol Platform and the Payment Services. This privacy policy describes our privacy practices for all websites, platforms and services that link to it. Please read the privacy policy on the applicable site.

1.1 Definitions

If you see an undefined term in this Privacy Policy (such as “Listing” or “Santa Ponsa Sol Platform”), it has the same definition as in our Terms of Service (“Terms”).

1.2 Data Controller

When this policy mentions “Santa Ponsa Sol,” “we,” “us,” or “our,” it refers to the Santa Ponsa Sol company that is responsible for your information under this Privacy Policy (the “Data Controller”).

1.3 Applicability to Payments

This Privacy Policy also applies to the Payment Services provided to you by Santa Ponsa Sol Payments pursuant to the Payments Terms of Service (“Payments Terms”). When using the Payment Services, you will be also providing your information, including personal information, to one or more Santa Ponsa Sol Payments entities, which will also be the Data Controller (the “Payments Data Controller”) of your information related to the Payment Services, generally depending on your country of residence.

If you change your country of residence, the Data Controller and/or Payments Data Controller will be determined by your new country of residence as specified above, from the date on which your country of residence changes. To this end the Data Controller and/or Payment Data Controller that originally collected your personal information will need to transfer such personal information to the new applicable Data Controller and/or Payments Data Controller due to the fact that such transfer is necessary for the performance of the contractual relationship with you.

Please see the Contact Us section below for contact details of the Data Controllers and Payments Data Controllers.

2. INFORMATION WE COLLECT

There are three general categories of information we collect.

2.1 Information You Give to Us.

2.1.1 Information that is necessary for the use of the Santa Ponsa Sol.

We ask for and collect the following personal information about you when you use the Santa Ponsa Sol Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

2.1.2 Information you choose to give us.

You may choose to provide us with personal information in order to obtain a better user experience when using Santa Ponsa Sol. This information will be processed based on our legitimate interest or when applicable, your consent.

2.1.3 Information that is necessary for the use of the Payment Services.

The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:

2.1.4 Information We Automatically Collect from Your Use of Santa Ponsa Sol.

When you use Santa Ponsa Sol, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of Santa Ponsa Sol.

2.1.5 Information We Collect from Third Parties.

Santa Ponsa Sol may collect information, including personal information, that others provide about you when they use Santa Ponsa Sol, or obtain information from other sources and combine that with information we collect through Santa Ponsa Sol. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

2.2 Children’s Data.

Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

3. HOW WE USE INFORMATION WE COLLECT

We may use, store, and process personal information to (1) provide, understand, improve, and develop Santa Ponsa Sol, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Santa Ponsa Sol Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.

3.1 Provide, Improve, and Develop Santa Ponsa Sol. We may use the personal information to provide, improve, and develop Santa Ponsa Sol such as to:

We process this personal information for these purposes given our legitimate interest in improving Santa Ponsa Sol and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:

We process this personal information for these purposes given our legitimate interest in protecting Santa Ponsa Sol, to measure the adequate performance of our contract with you, and to comply with applicable laws.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

3.4 How the Payments Data Controller uses the Personal Information Collected. We may use the personal information as a part of Payment services such as to:

The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

3.5 Your Choices

You have choices on the promotional messages that you choose to receive.

4. SHARING & DISCLOSURE

4.1 Advertising and Social Media; Sharing With Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Santa Ponsa Sol Account or when you participate in promotional activities conducted by Santa Ponsa Sol partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or Santa Ponsa Sol. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal information are not controlled or supervised by Santa Ponsa Sol. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

Please note that you may, at any time ask Santa Ponsa Sol to cease processing your data for these direct marketing purposes by sending an e-mail to david.hall@impacconsultancy.com.

4.2 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Santa Ponsa Sol may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Santa Ponsa Sol, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability (See more information on Santa Ponsa Sol’s Law Enforcement Guidelines here), (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Santa Ponsa Sol, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping Santa Ponsa Sol secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Santa Ponsa Sol’s property. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

4.3 Aggregated Data.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

5. OTHER IMPORTANT INFORMATION

5.1 Analyzing your Communications.

We may review, scan, or analyze your communications on Santa Ponsa Sol for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Santa Ponsa Sol’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

5.3 Third Party Partners & Integrations

Santa Ponsa Sol may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Santa Ponsa Sol doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Santa Ponsa Sol, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

Parts of Santa Ponsa Sol may use third party services such as Google Maps/Earth services, including the Google Maps API(s), and PayPal for Santa Ponsa Sol Payments. Use of these respective services is subject to their privacy policies such as Google Maps/Earth Additional Terms of Use, and the Google Privacy Policy, Citi Privacy Policy.

6. YOUR RIGHTS

Consistent with applicable law, you may exercise any of the rights described in this section before your applicable Santa Ponsa Sol Data Controller and Payments Data Controller. See here for information on data subject rights requests and how to submit a request. . Please note that we may ask you to verify your identity and request before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of your information through your Account settings. If you have chosen to connect your Santa Ponsa Sol Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Santa Ponsa Sol Account).

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:

6.5 Withdrawing Consent and Restriction of Processing.

If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to Santa Ponsa Sol specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Santa Ponsa Sol override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Santa Ponsa Sol not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Santa Ponsa Sol Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Santa Ponsa Sol to cease processing your data for these direct marketing purposes by sending an e-mail to david.hall@impacconsultancy.com.

6.7 Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.

7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS

To facilitate our global operations Santa Ponsa Sol may transfer, store, and process your information within our family of companies, partners, and service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

7.1 EU-US & Swiss-US Privacy Shield.

Santa Ponsa Sol comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom and Switzerland to the United States, respectively. Santa Ponsa Sol has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Under the Privacy Shield Framework, Santa Ponsa Sol are subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us via email. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or Commission or seek assistance from our designated Privacy Shield independent recourse mechanism, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.

If we have received your personal information under the Privacy Shield and subsequently transfer it to a third party service provider for processing as described in this Privacy Policy, we will remain responsible if these providers process your personal information in a manner inconsistent with the Privacy Shield Principles, except where we can establish that Santa Ponsa Sol was not responsible for the violation.

8. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Santa Ponsa Sol Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Santa Ponsa Sol Account, please contact us following the instructions in the Contact Us section below.

9. CHANGES TO THIS PRIVACY POLICY

Santa Ponsa Sol reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on Santa Ponsa Sol and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of Santa Ponsa Sol will be subject to the revised Privacy Policy.

10. CONTACT US

If you have any questions or complaints about this Privacy Policy or Santa Ponsa Sol’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at: david.hall@impacconsultancy.com.