MyDataMood General Privacy Policy

Data controller

Owner: MYDATAMOOD S.L.

TIN: B-88480983

Postal address: Avenida Alfonso XIII, nº 21, esc 1, puerta 2. 28002 Madrid (Spain)

Data protection e-mail: [email protected]

DPO e-mail: [email protected]

MyDataMood has appointed a Data Protection Officer (DPO) to be responsible for ensuring compliance with data protection regulations across the organisation: [email protected]

Information and consent

By accepting this Privacy Policy, the User is informed and hereby gives his or her free, informed, explicit and unequivocal consent for the personal data provided on the website located at the URL www.mydatamood.com (hereinafter, the "Website") to be processed by mydatamood.

Why do we process your data?

We process your data for the following purposes:

  • Manage our relationship with you. In other words, manage how we process and respond to your requests and queries, either using our forms or by e-mail.
  • Once you complete the registration form, we’ll manage your relationship as a user (mooder) of MyDataMood, which includes the different services offered on our platform:
    • Manage receipt of our Newsletter.
    • Manage communications about new services on the platform
    • As your representative, manage the exercise of your rights of access, rectification, objection, erasure, restriction and portability from our platform with the previously-selected organisations. Management may include our lodging a complaint on your behalf, as your representative, with the Supervisory Authority (Spanish Data Protection Agency or AEPD), if necessary
    • Manage the monetisation service of the data provided to the companies in the sectors of your choice once you’ve decided to make them available and join this service. (More information in the link to the specific Monetisation Privacy Policy).
    • Manage your relationship as a member of the Mooders Club (More information in the link to the specific Mooders Club Privacy Policy)

What is the lawful basis for processing your data?

The legal basis for processing your data is the express and unequivocal consent given when voluntarily requesting information about our platform and your relationship with MyDataMood as a registered user in relation to the following services:

  • When you ask us to represent you in exercising your right of access, objection, rectification, erasure, restriction and portability
  • When you use the monetisation service and decide to disclose certain information from your profile (such as your bio or your interests) to the companies (who work with us) in the sectors chosen by you
  • When you log on and become a member of the Mooders Club

However, you can choose not to receive information at any time and still continue to enjoy our services by sending an e-mail to [email protected] or clicking on the corresponding link in the e-mail you receive.

The consents obtained for the purposes mentioned above are independent, so as a user you can revoke just one of them without affecting the others.

What personal data of yours can we process?

The data you provide to us and the data subsequently generated during your relationship with MyDataMood.

  • When you fill in the contact form or send us an e-mail, we will process your name and e-mail address.
  • When you register your name, address, e-mail and ID number.
  • When you comment on the blog we’ll process your name.
  • When we represent you in exercising your right of access, objection, rectification, erasure, restriction and portability we will process the data that organisations send to you through us, in addition to the registered user data.
  • When you use the monetisation service, we’ll process your contact information (e-mail and telephone number) and all information that you voluntarily provide in your profile (gender, date of birth, level of education, address) or in the section on your interests (profession, family situation, hobbies, interest surveys, etc.). If there is a credit balance in your mooins account, we’ll also process your ID and zip code so you can download it for tax purposes.

The user’s responsibility

As User:

  • You declare that you are over 18 years of age and that the information you provide to MyDataMood is true, accurate, complete and up to date. As a User, you are responsible for the veracity of all the data you provide and for keeping the information up to date so that it reflects your real situation at any given time. The data can be updated in your user profile.
  • You agree that you will inform third parties from whom we may receive data in the process of exercising the right of access of the aspects contained in this document. You also agree that you will obtain their authorisation to enable MyDataMood to process the data for the stated purposes.
  • You are liable for any false or inaccurate information you provide on the website and for any direct or indirect damages that this may cause to MyDataMood or to third parties. Third parties are understood, in particular, as the companies in respect of which the foregoing rights are exercised and the companies in the sectors with which you agree to share your data as part of the monetisation service.

How long will we keep your data?

The collected data will be processed for the necessary amount of time and for the specific purposes for which they were collected. The information on contacts, registered users, blog comments will be kept as long as we do not receive any notice to the contrary, or consent is not revoked, and thereafter for the purpose of fulfilling legal obligations and liabilities arising from such processing in accordance with applicable law.

Data recipients

Unless it was necessary, in the cases provided by current regulations at all times, we do not share your information with any entity and / or person for whom we have not given your consent.

In the service of exercise of rights, we will only share with those companies or entities to whom you exercise said rights the data necessary to send the request for said exercise. In the monetization service, we only share your data with client companies belonging to the selected economic sectors, obtaining the corresponding economic benefit.

Although they do not imply data transfers, for different actions related to the treatments, we use providers that provide us services, and that may need to access your information; However, these providers manage the data for the sole purpose of providing us with the contracted service, following our instructions and without being able to use it for any other purpose.

These providers are:

  • Heroku: Development environment in the cloud of the MyDataMood platform. It is the technology platform support
  • PowerBI (Microsoft): data visualization tool
  • Google Workspace: Corporate Email Services
  • Freshdesk: incident management tool
  • SALESmanago: marketing management tool
  • Typeform: tool for creating forms and Landings
  • MessageBird: SMS sending tool
  • VIP DISTRICT S.L. .: Provider technology platform The Mooders Club
  • Amazon AWS & S3: Generated Document Storage Servers
  • Cookiebot: Cookie management tool

International data transfers

At first, there are no international data transfers to countries outside the Member States of the European Union.

In the case of provider services explained in the previous section, we have agreed to use servers in EU territory. And if in the future we hire other services located outside the territory of the EU we will take the necessary measures to ensure that such providers are subject to clauses approved by the European Commission, always informing previously.

What are your rights in relation to the processing of your data?

You can exercise your right to information, access, rectification, erasure, restriction on processing, opposition and portability and opt out of decisions based solely on the automated processing of your data, where applicable.

How can you exercise them?

The general procedure consists of sending an e-mail to [email protected] with the Reference "Exercise of rights". Proof of identity must be provided by enclosing a photocopy of your ID to make sure we are answering the data subject or his/her legal representative. In the latter case, proof of representation must also be provided.

If this message is being sent from the e-mail with which you registered, it is not necessary to send a copy of the ID card unless there is reasonable doubt about the applicant’s identity. In this case, you may be asked to send a copy of the ID card.

You are also informed that you have the right to file a complaint with our Data Protection Officer ([email protected]) or with the competent Supervisory Authority (Spanish Data Protection Agency) through its website (www.aepd.es) if you believe there has been any kind of violation in relation to the processing of your personal data.

Modification of Privacy Policy

We reserve the right to modify our Privacy Policy, attending to our own criteria, or motivated by a doctrinal change of the national Control Authority (Spanish Agency for Data Protection) or the European Data Protection Committee (CEPD), legislative or jurisprudential. Any modification of the Privacy Policy will be publicized on the home page and through a specific communication to our users. The use of the web after said changes will imply the acceptance of them.

Last updated: April 2021.

Privacy policy specific to the monetization service

Data controller

Owner: MYDATAMOOD S.L.

TIN: B-88480983

Postal address: Avenida Alfonso XIII, nº 21, esc 1, puerta 2. 28002 Madrid (Spain)

Data protection e-mail: [email protected]

DPO e-mail: [email protected]

MyDataMood has appointed a Data Protection Officer (DPO), who is the person responsible for ensuring compliance with data protection regulations in the organisation: [email protected]

Purpose of processing

The sole purpose of the monetisation service (which requires prior registration as a user) is to voluntarily provide certain data to be used by companies in the chosen sectors to offer their products and services that may be of interest to you. In exchange, you benefit economically from the information that we market to our client companies in a transparent and controlled manner.

The products and services offered by the client companies that have received your data from us may be offered to you by phone and by e-mail.

There is a single monetisation mode consisting of free subscriptions sponsored by MyDataMood to specific products or services of collaborating entities in which the user may be interested, for a certain period of time. This type of monetisation consists of MyDataMood paying the cost of your subscription for the specified number of months, as long as you voluntarily provide certain requested data (based on the completed questionnaire) to be used for three months by the companies in the sectors from which you agreed to receive product and service offers.

In keeping with the principle of transparency, you are hereby informed that in order to participate in the monetisation service you must register as a user on our platform (mooder).

MyDataMood guarantees that your data will not be used for any other purpose as part of this service.

Origin and type of data

The types of personal data we use in monetisation processing are limited to the ones provided by you when you sign up for the service and participate in the campaigns of your choice:

  • Identifiers: first and last name, e-mail, phone number and zip code
  • Data related to the product or service you are interested in (type of product you are interested in, month you expect to purchase it, new contract or non-renewal of the current one)
  • For certain monetisation services through sponsorships (sponsored subscriptions), it is also necessary to complete a questionnaire about interests and preferences aimed at future promotions of goods or services in different sectors (telecommunications, insurance, banking, etc.).

Lawful basis for processing

The legal basis for processing your data is the express and unequivocal consent given when voluntarily requesting to participate in the monetisation service and your relationship with MyDataMood as a registered user in relation to the following services: (which includes the monetisation service, among others).

Data retention

Personal data provided by registered users will be used as long as we receive no opposition. However, the minimum retention period is 3 months from your request to participate in the service, after which we will delete the data for the sectors that are no longer of interest to you, or remove them from the service entirely when you no longer wish to continue monetising your data.

For the different monetisation services (sponsorships) you must comply with the minimum times indicated in the terms and conditions of the sponsorship. However, below is an explanation of the times and how they are calculated for the monetisation service:

  • The minimum length of the monetisation service is 3 months, which means you cannot revoke your consent during that time (while you monetise your contact details or enjoy your sponsored subscription you can be impacted by the companies in the sectors you have chosen).
  • If during those 3 months there are companies that access your data for advertising purposes, you’ll be able to see it on the platform. In that case, the 3 months are calculated starting when the companies acquire your contact information (the acquisition date of your information by our client company appears on the platform). In other words, when a client company accesses your data, it has 3 months to send you commercial messages, after which the permission to share your information is automatically revoked.

Data recipients

Data transfers

Unless legally required, in relation to this treatment, we only share your data with client companies belonging to the selected economic sectors, obtaining the corresponding economic benefit. In addition, in the case of monetization through sponsorship (sponsored subscriptions), we will only transfer your data (strictly necessary) to the collaborating company that offers the sponsored service of your interest so that it can offer said service.

Data processors with access to your data:

MyDataMood uses the service providers identified in the MyDataMood Privacy Policy. If you want to know who they are, you can see a list in the general Privacy Policy.

On the other hand, the customers or collaborating entities with which we share your data may in turn use data processors who may only access your data in the name and on behalf of the company that commissioned them, following their instructions and without permission to use them for any other purpose.

International data transfers

Your data will not be the object of international transfers (non-European Economic Area (EEA) countries)

Data security and confidentiality

MyDataMood is committed to the secure and confidential processing of your data and to implementing the appropriate technical and organisational measures according to the level of risk that such processing may pose to the rights and freedoms of the people whose data are processed.

The implementation of the necessary security measures is accompanied by a subsequent process of regular verification, evaluation and assessment of the effectiveness of these measures (continuous improvement to ensure secure data processing).

Strict confidentiality in the processing of personal data is considered an imperative obligation for the staff of MyDataMood, who’ve made a commitment to secrecy at all stages of processing in keeping with the laws in force.

What are your rights in relation to the processing of your data?

You can exercise your right to information, access, rectification, erasure, restriction on processing, opposition and portability and opt out of decisions based solely on the automated processing of your data, where applicable.

How can you exercise them?

The general procedure consists of sending an e-mail to [email protected] with the Reference "Exercise of rights". Proof of identity must be provided by enclosing a photocopy of your ID to make sure we are answering the data subject or his/her legal representative. In the latter case, proof of representation must also be provided.

If this message is being sent from the e-mail with which you registered, it is not necessary to send a copy of the ID card unless there is reasonable doubt about the applicant’s identity. In this case, you may be asked to send a copy of the ID card.

You are also informed that you have the right to file a complaint with our Data Protection Officer ([email protected]) or with the competent Supervisory Authority (Spanish Data Protection Agency) through its website (www.aepd.es) if you believe there has been any kind of violation in relation to the processing of your personal data.

Use of cookies

Access our MyDataMood Cookies Policy.

Last updated: April 2021.

Specific Mooders Club Privacy Policy for Mooders Club users

If you are registered or thinking of registering on the MOODERS CLUB platform, this information is for you:

Who is the data controller?

Identity: MYDATAMOOD S.L.

Postal address: Avenida Alfonso XIII, nº 21, esc 1, puerta 2. 28002 Madrid (Spain)

E-mail address: [email protected]

Contact the DPO: [email protected]

MYDATAMOOD, S.L. (hereinafter, MyDataMood) has engaged the services of the MOODERS CLUB platform managed by VIP DISTRICT S.L. (hereinafter, COLECTIVOS VIP). COLECTIVOS VIP is a service provider that allows MYDATAMOOD to offer its users (mooders) privileged access to services, special offers and advantageous promotions. As a registered user, you can browse the MOODERS CLUB platform to take advantage of the services.

COLECTIVOS VIP will process the platform’s personal data as the data processor on behalf of MyDataMood as the data controller.

Scope of application

The information contained in this policy applies exclusively to user data processed by the MOODERS CLUB platform, as detailed in this document, which cannot be extended to apply to other websites or processing by MyDataMood.

1. When do we collect your personal data?

Personal data are collected on the MOODERS CLUB platform in the following situations:

  • At the time of registration: when you register we’ll ask you to provide information to identify yourself and set up your profile.

2. Why do we process your personal data?

The first thing we do is process your personal registration data to confirm that you’re a member of the Mooders Club and that you meet the requirements to access the platform.

We will use the data you provide to manage your profile.

We will only use your contact information (e-mail) to send you information about new offers, discounts and promotions published in the Mooders Club with your explicit consent. To that end, when you register we’ll ask you if you want to receive e-mail messages from us with commercial offers.

You can always unsubscribe from the Newsletter you receive. All of our communications contain a link that allows you to unsubscribe and stop receiving this type of e-mail.

Whenever you make a purchase on our platform, we may process data about the transaction for the sole purpose of managing it.

Please also note that your anonymised data will be processed for statistical purposes.

3. How long do we keep your personal data?

We will process your personal data as long as you continue to be a user (mooder) of MyDataMood. Once cancelled, we will block and retain the data as needed for the fulfilment of legal obligations, for the amount of time necessary to defend against possible claims and to comply with any legal obligations created.

4. What if the data pertain to a minor?

The type of service we offer is for adults only, so we do not anticipate being contacted by minors through the website. However, if you as a parent or legal guardian believe that your child or ward has sent us their personal data, please contact us by sending an e-mail to [email protected]

5. What is the lawful basis for processing your personal data?

To become a member of the Mooders Club and benefit from offers, discounts and promotions that may be of interest to you, you have previously registered with MyDataMood. Therefore the lawful basis is consent.

When you request products or services from suppliers in the course of your activity, we will process your data for the fulfilment of the established contractual relationship.

It’s possible that legal obligations may arise from your activity, so this is a lawful basis for us to process your data.

Finally, we may also process your data based on the lawful interest of MyDataMood, e.g., to inform you of new discounts, offers and promotions on the platform.

6. To whom can your data be disclosed?

Sometimes, when you purchase products or services from suppliers on the platform, we may share your data with the supplier as needed to manage the transaction, with your prior consent. You can use the website to access the services and promotions managed directly by our suppliers, which means that you’ll be taken directly to the supplier’s URL to complete the transaction and there may be and exchange of information between the two of you. We recommend that whenever a link redirects you outside our platform you read the privacy policy of the provider carefully.

We at MyDataMood can assure you that we’ve conducted a prior analysis of the providers listed in the Mooders Club so to allow only the ones that guarantee compliance with personal data protection laws (RGPD and LOPDyGDD). However, we decline any liability for any fine or non-compliance by providers.

You are hereby informed that when your data are housed in our system, they will be processed by service providers who act as sub-processors.

7. What are your rights when you provide us with personal data?

If we process your data, you should know that your rights are:

  • Right to request access to personal data: you can ask us if we are processing your data and, if so, ask to access them.
  • Right to request correction of inaccurate data or to complete any incomplete data.
  • Right to request the erasure of your data.
  • Right to request limitations on processing: in this case, they will only be retained for the purpose of lodging or defending complaints.
  • Right to oppose processing: we will stop processing personal data, except to the extent that processing must continue for legitimate reasons or to lodge or defend complaints.
  • Right to data portability: if you want your data to be processed by another data controller, we will facilitate the transfer of your data to the new controller.
  • Right to opt out of decisions based solely on the automated processing of your personal data.

To exercise your rights you can contact us directly using the contact details listed at the top of this document or you can send an e-mail to MyDataMood at the following address: [email protected]

At MyDataMood, we process data on the basis of consent and you should know that you have the right to withdraw your consent at any time without affecting the lawfulness of the processing carried out prior to the withdrawal.

If you consider it appropriate, you can file a complaint with our Data Protection Officer ([email protected]) or with the Spanish Data Protection Agency (www.aepd.es).

Remember that your data must be truthful and accurate and you must keep it up to date.

8. How did we obtain your data?

The personal data that we will process from the platform is the data that you provide at the time of registration and during the course of the relationship.

9. Modifications

We will only use your personal data as established in this document, which is in effect at the time we collect your information. If MyDataMood makes any change to the way in which your data are processed, we will inform you in a timely manner.

Last updated: April 2021.