PRIVACY POLICY

BASIC INFORMATION ON DATA PROTECTION
Responsible: THE CLUELESS AIGENCY S.L.
Purpose: Provision of online services, web user management, commercial communications related to our services.
Legitimation: Express consent and legitimate interest.
Addressees: No data is transferred to third parties, unless legally required.
Rights: Access, rectify and delete data, as well as other rights, as explained in the additional information.
Additional information: You can consult the additional and detailed information on Data Protection in the attached clauses found at www.theclueless.ai/privacy-policy.

In THE CLUELESS AIGENCY S.L., we work to provide you with the best possible experience through our products and services. In some cases, it is necessary to collect information to achieve this goal. We care about your privacy and believe that we should be transparent about it.

Therefore, in accordance with the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (hereinafter, "GDPR") regarding the protection of individuals with regard to the processing of personal data and on the free movement of such data, and LAW 34/2002, of 11 July, on Information Society Services and Electronic Commerce (hereinafter, "LSSI"), THE CLUELESS AIGENCY S.L. informs the user that, as the data controller, it will incorporate the personal data provided by users into an automated file.

Our commitment begins by explaining the following:
· Your data is collected so that the user experience can improve, catering to your interests and needs.
· We are transparent about the data we obtain about you and the reason why we do so.
· Our intention is to offer you the best possible experience. Therefore, when we are going to use your personal information, we will always do so in compliance with regulations, and when necessary, we will request your consent.
· We understand that your data belongs to you. Therefore, if you decide not to authorize us to process it, you can request that we stop processing it.
· Our priority is to ensure your security and to treat your data in accordance with European regulations.

If you wish to obtain more information about the processing of your data, please refer to the various sections of the privacy policy outlined below:

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
Identity: THE CLUELESS AIGENCY S.L.
Registered Address: Calle Jericó 3, Local
Tax Identification Number (C.I.F.): B56701212
Email: stuff@theclueless.ai

THE CLUELESS AIGENCY S.L. has appointed an internal contact person within its organization. If you wish to make an inquiry regarding the processing of your personal data, you can contact them via the email stuff@theclueless.ai.

WHAT PERSONAL DATA DO WE COLLECT?
The personal data that the user may provide includes:
· Name and address.
· Phone number and email address.
· Location.
· Information regarding payments and refunds.
· IP address, date and time of access to our services, internet browser used, and data about the device's operating system.
· Any other information or data that you decide to share with us.

In some cases, completing the registration form is mandatory to access and enjoy certain services offered on the website. Additionally, not providing the requested personal data or not accepting the present data protection policy may result in the inability to subscribe, register, or participate in any promotions that require personal data.

WHY DO WE PROCESS YOUR DATA AND FOR WHAT PURPOSE?
In THE CLUELESS AIGENCY S.L., we process the information provided by interested individuals for the following purposes:
· Managing orders or contracting any of our services, whether online or in physical stores.
· Managing the sending of requested information.
· Developing commercial actions and maintaining and managing the relationship with the user, as well as managing the services offered through the website and information tasks. This may include conducting automatic assessments, obtaining profiles, and segmenting customers in order to personalize treatment according to their characteristics and needs and improve the online customer experience.
· Developing and managing contests, giveaways, or other promotional activities that may be organized.
· In some cases, it may be necessary to provide information to authorities or third-party companies for audit purposes, as well as to handle personal data from invoices, contracts, and documents to respond to customer claims or requests from public authorities.

We inform you that the personal data obtained as a result of your registration as a user will be part of the Register of Activities and Treatment Operations (RAT), which will be periodically updated in accordance with the provisions of the GDPR.

WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?
The processing of your data may be based on the following legal grounds:
· Consent of the data subject for contracting services and products, for contact forms, requests for information, and subscription to newsletters.
· Legitimate interest for processing data of our customers in direct marketing actions related to similar services previously contracted.
· Compliance with legal obligations for fraud prevention, communication with public authorities, and third-party claims.

HOW LONG DO WE KEEP YOUR DATA?
The processing of data for the purposes described will be maintained for the time necessary to fulfill the purpose of its collection (for example, for the duration of the business relationship), as well as for compliance with legal obligations arising from the processing of the data.

TO WHOM ARE YOUR DATA DISCLOSED?
In some cases, only when necessary, THE CLUELESS AIGENCY S.L. will provide user data to third parties. However, data will never be sold to third parties.

External service providers with whom THE CLUELESS AIGENCY S.L. works may process data in order to provide the corresponding services, including:

Mailchimp (The Rocket Science Group LLC) for email marketing and newsletter distribution.
Stripe Payments Europe Ltd. for payment processing on some of our websites and services.
These providers act as data processors under our instructions and under appropriate data processing agreements.

THE CLUELESS AIGENCY S.L. ensures that any international data transfers are carried out with appropriate safeguards in accordance with Articles 44 to 49 of the GDPR, such as the use of Standard Contractual Clauses approved by the European Commission.

In some cases, the law may require that personal data be disclosed to public authorities or other parties, only the strictly necessary information will be disclosed to fulfill such legal obligations.

Personal data obtained may also be shared with other companies within the corporate group.

WHERE ARE YOUR DATA STORED?
As a general rule, data is stored within the European Union.
Data transferred to third parties outside the EU will be protected through appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, ensuring an adequate level of data protection.

WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU EXERCISE THEM?
You may exercise your rights by sending a request to: stuff@theclueless.ai

Under the GDPR, you may request:
· Right of access
· Right of rectification
· Right to erasure (right to be forgotten)
· Right to restriction of processing
· Right to object
· Right to data portability
· Right not to be subject to automated individual decision-making

You may also lodge a complaint with the Spanish Data Protection Authority (AEPD) if you consider that your rights have not been properly respected.

WHO IS RESPONSIBLE FOR THE ACCURACY OF THE PROVIDED DATA?
The user is solely responsible for the accuracy and correctness of the included data, releasing THE CLUELESS AIGENCY S.L. from any liability in this regard.

Users guarantee and respond, in any case, to the accuracy, currency, and authenticity of the provided personal data and commit to keeping it duly updated.

HOW DO WE HANDLE PERSONAL DATA OF MINORS?
Our services are not specifically aimed at minors.
In accordance with Article 8 of the GDPR and Article 7 of the LOPDGDD, minors under the age of 14 require the consent of their legal guardians.
Minors over the age of 14 may provide consent themselves, except in cases where the law requires parental assistance.

WHAT SECURITY MEASURES DO WE APPLY?
THE CLUELESS AIGENCY S.L. has adopted the legally required security measures and applies appropriate technical and organizational safeguards to protect personal data.

However, users should be aware that security measures on the Internet are not impregnable.

LINKS TO OTHER WEBSITES
Our website may contain links to third-party websites. THE CLUELESS AIGENCY S.L. is not responsible for the privacy practices of such external websites.

HOW DO WE USE COOKIES?
THE CLUELESS AIGENCY S.L. uses cookies in accordance with our Cookie Policy available at:
www.theclueless.ai/cookie-policy

CAN THIS PRIVACY POLICY BE MODIFIED?
This privacy policy may be updated. We recommend reviewing it periodically.

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