PRIVACY POLICY

This privacy policy (hereinafter, the “Privacy Policy”) informs you about the data processing carried out at ZarpoApps S.L. for the Users (the “Users”) who visit the website (hereinafter, the “Website” or the “Site”). ZarpoApps S.L. values your trust as a User and your privacy, and for this reason explains below how your data is processed. If you have any questions or would like more information on this, you can write to ZarpoApps S.L. at the following address: legal@zarpo.io

1. WHO IS THE CONTROLLER OF YOUR DATA?

The data controller is whoever decides the purpose for which your personal data is used, in this case, ZarpoApps S.L. (“Zarpo”), with CIF (tax ID) B21857602 and registered office at Rec Comtal 12, 3-3, 08003 Barcelona, Spain

2. WHAT DATA DOES ZARPO PROCESS?

Personal data (“Data”) is any information about an identified or identifiable natural person (the “Data Subject” or “Holder of the Data”). The personal data that Zarpo processes comes from the information that you, as a User, provide to us when filling in the forms you will find on the Website, when browsing the Website and/or when sending us your queries or requests for information.

In each form, Zarpo uses an asterisk to indicate the contact data it needs as mandatory in order to deal with your query or request. Data not marked as mandatory with an asterisk is entirely optional. Only the data needed for each purpose is collected. Please bear in mind that, if you do not provide the mandatory information, Zarpo may be unable to deal with your query or request or to manage the processing.

To provide the Services, Users may give us descriptions and photographs (the “Content”) that may contain personal data about themselves and/or third-party Data Subjects. In that case, we will process the personal data solely to provide the requested Service and for the time necessary in accordance with this Policy. By uploading Content, you expressly declare that you have the authorisation and/or legal standing to use it for the provision of the Services. If the Content contains data about minors, you confirm that you have the authorisation of the holders of parental authority and/or their legal guardians to do so. In any case, Zarpo safeguards the privacy of its Users and processes such data only for the creation of the Product and never for profiling or advertising purposes. We recommend that uploaded images do not contain geolocation data or sensitive information in the background.

Please bear in mind that it is your responsibility to provide truthful Data and keep it up to date, so Zarpo reserves the right to exclude from the services, and/or to cancel them for, Users who provide false or incorrect Data or Data without the due authorisation of the Data Subject, without prejudice to our right to bring whatever legal actions may be appropriate.

3. FOR WHAT PURPOSE DOES ZARPO PROCESS THE DATA?

Zarpo will process the Data for the following purposes:

1. A. CREATE YOUR BOOK. When you create your Product, Zarpo may use your Data to manage the Service, manage the purchase and your account, send you the product, and comply with the applicable legal obligations. Zarpo will also use your data to contact you in relation to the Service and to offer you offers and additional information about Zarpo related to it.
2. B. CONTACT. If you contact Zarpo through the channels provided for this purpose, by email or by any other means made available to you, Zarpo will use the contact data and details you provide to deal properly with your queries or requests, which includes the possibility of contacting you by different means and forwarding them to the relevant persons in charge so that they can reply to you.
3. C. BROWSING OUR WEBSITE. Through the use of cookies and other technologies, Zarpo may take measurements and analyse browsing traffic, usability and your experience as a User on the Website on a statistical basis. The installation and use of cookies depends on the settings you choose both in the cookie banner and through your browser.
4. D. MARKETING WITH CUSTOMER TESTIMONIALS. When you expressly authorise it, Zarpo may use images, extracts or the content of your Product, as well as your name or initials if you so consent, for Zarpo’s marketing and promotional purposes, including publishing them on the website, on Zarpo’s own social networks and in email communications. This processing will only take place if you give your express and specific consent for it, after delivery of your Product, and you may withdraw it at any time.

4. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

The legal basis for processing your Data to provide our Services and manage your account is the performance of the contract of sale and compliance with legal obligations (for example, the tax reporting of contributions to Zarpo).

The legal basis for contact with Zarpo is the consent you have given by registering in the corresponding forms. In some cases, the processing of your Data when you contact Zarpo may be based on taking pre-contractual steps if these are necessary to deal with the query.

Please bear in mind that, if you are a buyer of Zarpo’s products and/or services, we may also send you communications based on our legitimate interest in offering you improvements, offers and activities that may interest you and keeping you informed about the various Zarpo activities and initiatives that we believe may be of interest to you.

The legal basis for processing your data in connection with browsing the Website is the consent you give when the installation of cookies is accepted, which you can withdraw or configure at any time through the settings panel. You can find more information about the use of cookies in Zarpo’s Cookie Policy.

Remember that you can withdraw your consent at any time. You may also object to continuing to receive commercial communications in the manner indicated in the footer of each communication.

The legal basis for using your Product, images or testimonial for marketing purposes is your express consent, which we will ask you for specifically and separately after delivery of the Product, in accordance with Article 6.1.a) of Regulation (EU) 2016/679. You may withdraw this consent at any time, without affecting the lawfulness of the prior processing. Withdrawal will mean that use of your content in new publications stops and that, within a maximum period of 30 days, it is removed from Zarpo’s own channels (website, social networks and communications), but this does not extend to shares already made by third parties unrelated to Zarpo.

5. HOW LONG IS THE DATA KEPT?

The Data will be kept for the period necessary for the purpose for which it was collected, and specifically:

1. a. We keep your account data while your account is active. If you delete your account, we will delete your personal data within 30 days, unless we are required to keep it for legal or tax compliance reasons.
2. b. Content is only stored during the Product generation process. The AI-generated character illustrations (not your original photos), stories and other Content relating to the creation of the Product are stored in your account for use in generating the Product, for as long as you do not delete them or delete the account. This Content is yours, and we store it solely to allow you to access, review and order your personalised Product.
3. c. With regard to the Data you provide to Zarpo to make queries or get in touch with Zarpo, we will process the data for as long as necessary to answer your query or request and/or give you access to the services, and, where applicable, for the time necessary to be able to deal with any possible claims or queries on your part.
4. d. With regard to web browsing Data, until you withdraw your consent and for a maximum period of 1 year. In any case, information about web traffic is deleted periodically, so that Zarpo will keep only anonymised statistical usage data (without identification of Users).
5. e. Content and images used for marketing purposes, with your prior express consent, will be kept for as long as that consent is not withdrawn and, in any case, for as long as they are necessary for the promotional purpose for which they were authorised.

Once the data is no longer necessary for the purpose for which it is processed, it will remain blocked for the sole purpose of meeting any liability or obligations that may arise from its processing.

6. TO WHICH RECIPIENTS WILL YOUR DATA BE DISCLOSED?

Your data may be disclosed to service providers that help Zarpo carry out its activity, such as third-party services for operating our Site, including: authentication for account management; secure card payment processing through a virtual point-of-sale terminal; printing and shipping of products; and artificial intelligence tools for generating stories and illustrations. Our list of providers is available to you at the following link: List of Providers.

The Content will not be used for model training, advertising or profiling.

When the User requests a physical copy of the Book, Zarpo will disclose to its printing providers and/or to the transport and logistics companies in charge of delivery the data strictly necessary for the proper fulfilment of the order, which will generally include the recipient’s first name and surname(s), full delivery address and, where applicable, contact telephone number.

Those providers will act, as the case may be, as data processors (in which case they will have signed with Zarpo the corresponding data processing agreement in accordance with Article 28 of the GDPR) or as independent controllers as regards the transport and delivery service.

Some of the providers mentioned are established outside the European Economic Area (EEA), which involves an international transfer of personal data. When your data leaves the EEA, it will keep the same level of protection required by European data protection legislation. International data transfers will take place only (i) to countries with an adequate level of protection declared by the European Commission, (ii) on the basis of appropriate safeguards (standard contractual clauses or other safeguards provided for in Article 46 of the GDPR), or (iii) under other cases provided for in the legislation.

To receive more information about international data transfers or to obtain a copy of the safeguards used, you can contact Zarpo at legal@zarpo.io

Where necessary to comply with Zarpo’s legal obligations, the data may be disclosed to the Public Administration and to the State Security Forces and Corps.

7. REGISTRATION AND FOLLOWING OF CORPORATE SOCIAL NETWORK ACCOUNTS ON THE WEBSITE

In the case of the profiles that Zarpo maintains on the various social networks linked from this Site, for example through third-party plugins or applications, your data may be processed under other privacy policies of the owners of those social networks.

The use of those connectors is voluntary. If you choose to use them, you will be authorising the disclosure of your personal data (IP address, browsing data) to the social networks referred to, and Zarpo will not be responsible for any further processing they may carry out with your data. Zarpo recommends that you visit the terms and conditions of use of those platforms before interacting on social networks with Zarpo’s profiles on those social networks.

The profiles on the social networks linked from this Site have been created so that you can get to know our activity better and to offer different communication channels for people interested in our entity and the services we offer.

8. SECURITY MEASURES

Zarpo is particularly concerned with guaranteeing the security of personal Data. The Data is stored in Zarpo’s information systems, where it has adopted and implemented technical and organisational security measures to prevent any loss or unauthorised use by third parties; for example, Zarpo’s web portals use Https data encryption protocols.

The Content uploaded to generate illustrations is processed by the artificial intelligence providers indicated in our list of providers (including Google, through its Gemini service), for the sole purpose of generating the illustrations for your Product. We do not store these images permanently on our own systems once the generation process has finished, and we do not use them to train artificial intelligence models or for advertising profiling.

9. WHAT ARE YOUR RIGHTS?

As the holder of your Data, you can request confirmation of whether your personal data is being processed and, if so, access it. You can also request the rectification of inaccurate data or, where applicable, request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, you may request the restriction of the processing of your data, in which case we will keep it only for the exercise of actions or the defence of claims.

You can withdraw the consents you have given at any time. Once withdrawal has been exercised, which will not have retroactive effect unless a legal provision imposes such effect, your data may be kept blocked for the limitation periods established by the applicable rules.

Remember that you may also object to the processing of your data, in particular with regard to commercial communications, in which case we will not process the data, except for compelling legitimate grounds or for the exercise or defence of possible claims.

To exercise these rights, write, attaching a copy of a document proving your identity, to legal@zarpo.io

To help us process your request, please put “Data Protection” in the subject line.

Likewise, if you have any doubts about the exercise of your rights, before approaching the supervisory authority, we remind you that, if you wish, you can ask us directly by writing to us and we will try to help you in the best way possible.

Finally, we remind you that you have the right to lodge a complaint with the competent data protection authority (in Spain, www.aepd.es) if you become aware of or consider that a fact may amount to a breach of the applicable data protection legislation.

10. ANNEX: List of providers