PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy explains how WEBOVO, referring to WEBOVO S.L., a company established in Spain under NIF number B13922646 (“WEBOVO”, “we”, “us”, or “our”) collects, uses, stores, discloses and otherwise processes personal data in connection with:

• the website available at https://webovo.net/ (the “Website”);
• consultation enquiries and requests submitted through the Website;
• communications with prospective and existing clients;
• the provision and administration of WEBOVO consulting services;
• the WEBOVO Client Portal, where applicable; and
• other business interactions with WEBOVO that are covered by this Privacy Policy.

WEBOVO provides professional consulting services in the areas of Workplace Safety, Online Security, and AI & Business.

This Privacy Policy is intended to provide transparency regarding our processing of personal data. Where the General Data Protection Regulation (“GDPR”), UK GDPR, or another applicable data protection law applies, personal data will be processed in accordance with the requirements applicable to the relevant processing activity.

This Privacy Policy should be read together with the WEBOVO Cookie Policy and any privacy terms contained in a specific proposal, engagement letter, statement of work, data processing agreement, or other agreement applicable to a particular Client engagement.

2. WHO WE ARE

WEBOVO is the brand through which the Website and the consulting services described on it are provided.

For the purposes of applicable data protection law, the relevant data controller is:

Where applicable law requires the identification of a local representative or Data Protection Officer, the relevant details will be provided.

3. OUR ROLE AS CONTROLLER OR PROCESSOR

For personal data relating to Website visitors, prospective clients, business contacts, consultation requests and WEBOVO's own administration, WEBOVO will generally act as a data controller where applicable data protection law uses that concept.

In some consulting engagements, a Client may provide WEBOVO with personal data that WEBOVO is instructed to process solely on that Client's behalf.

In those circumstances, depending on the nature of the engagement and applicable law, WEBOVO may act as a processor or service provider rather than as an independent controller.

Where WEBOVO processes personal data on behalf of a Client, the relevant processing may be governed by:

• the applicable engagement agreement;
• a statement of work;
• a data processing agreement;
• documented Client instructions; or
• other contractual arrangements between WEBOVO and the Client.

This Privacy Policy principally describes personal data processed by WEBOVO for its own purposes as a controller.

4. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies, where relevant, to personal data relating to:

4.1 Website Visitors

Individuals who visit or interact with the Website.

4.2 Prospective Clients

Individuals who submit an enquiry, request a consultation, ask for information about WEBOVO's services, or otherwise contact WEBOVO regarding a potential engagement.

4.3 Existing Clients and Business Contacts

Individuals who communicate or interact with WEBOVO in connection with an existing business or consulting relationship, including employees, directors, representatives, contractors and authorised contacts of Client organisations.

4.4 Client Portal Users

Individuals who are authorised to access the WEBOVO Client Portal, where such access is provided.

This Privacy Policy does not govern the independent privacy practices of third-party websites, platforms, products or services that may be linked to or used in connection with the Website.

5. PERSONAL DATA WE MAY COLLECT

The personal data WEBOVO processes depends on how you interact with us.

We seek to process only personal data reasonably necessary for the relevant purpose.

The categories described below may not apply to every individual.

6. DATA YOU PROVIDE DIRECTLY

You may provide personal data directly to WEBOVO when you:

• submit a consultation request;
• complete a Website contact form;
• communicate with us by email;
• request information about our Services;
• arrange or participate in a consultation;
• represent a business or organisation in communications with WEBOVO;
• enter into or administer a consulting engagement;
• use the Client Portal, where applicable; or
• otherwise communicate with WEBOVO.

Depending on the circumstances, this may include:

• your name;
• business email address;
• organisation or company name;
• job title or professional role, where provided;
• contact details;
• the service you are interested in;
• preferred consultation date;
• preferred consultation time;
• information contained in your enquiry or message;
• correspondence with WEBOVO;
• information reasonably necessary to arrange or administer a consultation; and
• other information that you voluntarily choose to provide.

We do not ask you to provide information that is unnecessary for the purpose of your enquiry.

7. CONTACT AND CONSULTATION REQUEST DATA

The Website provides a form through which visitors may contact WEBOVO or request a consultation.

The form may request information including:

• Full Name;
• Email Address;
• Company / Organisation;
• requested Service;
• Preferred Date;
• Preferred Time; and
• Message.

Service selections may include enquiries relating to:

• French Speaking Initial Consultation;
• English Speaking Initial Consultation;
• Workplace Safety Consulting;
• Online Security Consulting;
• AI & Business Consulting; and
• General Enquiries.

WEBOVO may use this information to:

• review your enquiry;
• understand the nature of your request;
• determine whether WEBOVO may be able to assist;
• respond to you;
• discuss the appropriate consultation scope;
• confirm availability;
• arrange a consultation;
• prepare for a potential engagement; and
• maintain appropriate records of business communications.

Submitting a consultation request does not by itself create a binding consulting engagement.

8. BUSINESS CONTACT AND CLIENT DATA

Where you are an existing Client or act on behalf of a Client organisation, WEBOVO may process business contact and engagement-related information such as:

• name;
• professional contact information;
• employer or organisation;
• job title or role, where relevant;
• authority or responsibility within the organisation;
• business correspondence;
• meeting and consultation information;
• service requirements;
• engagement administration information;
• records relating to agreed scope and deliverables;
• information relevant to providing requested consulting services; and
• records necessary to manage the professional relationship.

Depending on the engagement, WEBOVO may also receive business contact information from your employer, colleagues, authorised representatives, professional advisers, or another person who introduces your organisation to WEBOVO.

WEBOVO will process such information only where there is an appropriate purpose and legal basis for doing so.

9. INFORMATION RELATING TO CONSULTING SERVICES

WEBOVO provides consulting services relating to:

• Workplace Safety;
• Online Security; and
• AI & Business.

In the course of an engagement, a Client may provide information concerning its organisation, processes, systems, risks, personnel, technology or business operations.

Some of that information may contain personal data.

The nature and extent of personal data required will depend on the relevant engagement.

Clients should avoid providing personal data that is not reasonably necessary for the agreed consulting purpose.

Where an engagement requires WEBOVO to process personal data supplied by a Client on the Client's behalf, appropriate contractual or data-processing terms may apply.

10. SENSITIVE, CONFIDENTIAL AND SECURITY-RELATED INFORMATION

WEBOVO's Website contact form is intended for general enquiries and consultation requests.

Unless WEBOVO specifically requests information through an appropriate approved channel, you should not submit through the general Website contact form:

• passwords;
• authentication credentials;
• access tokens;
• private cryptographic keys;
• security codes;
• payment-card credentials;
• highly sensitive personal information;
• unnecessary health information;
• government-issued identification documents;
• trade secrets;
• confidential security configurations;
• vulnerability information that could create an immediate security risk;
• confidential information belonging to another person or organisation where you are not authorised to disclose it; or
• any other information that is not reasonably necessary for your enquiry.

WEBOVO does not request passwords, private keys or similar security credentials through the general Website enquiry form.

If sensitive or confidential information is relevant to a consulting engagement, WEBOVO may provide or agree an appropriate method for exchanging such information.

11. CLIENT PORTAL DATA

WEBOVO provides a Client Portal at:

https://webovo.net/client-portal/index.html">https://webovo.net/client-portal/index.html

Where you are provided with access to the Client Portal, WEBOVO may process information reasonably necessary to establish, administer and secure your account, which may include:

• your email address;
• account identifiers;
• authentication information;
• account-security information;
• login and access records, where generated;
• information relating to account administration; and
• information associated with functionality made available to you through the Client Portal.

The exact categories of information processed through the Client Portal depend on the functionality made available to the relevant Client or user.

You are responsible for keeping your login credentials confidential and should contact WEBOVO promptly if you believe your account or credentials have been compromised.

You should not attempt to access another person's or organisation's Client Portal account without authorisation.

12. DATA COLLECTED AUTOMATICALLY

When you access the Website or Client Portal, certain technical information may be generated or processed automatically to the extent necessary for Website delivery, operation, security, diagnostics or administration.

Depending on the Website's technical configuration and the service providers involved, such information may include:

• Internet Protocol (IP) address;
• browser type and version;
• device type;
• operating system;
• date and time of access;
• pages or resources requested;
• referring page or source;
• basic Website interaction information;
• server logs;
• authentication or security events; and
• diagnostic or error information.

Not every category listed above will necessarily be collected in every case.

WEBOVO does not state that it uses behavioural profiling, targeted advertising or similar technologies unless and until such processing is implemented and appropriately disclosed.

Further information concerning cookies and similar technologies is provided in the Cookie Policy.

WEBOVO does not currently use automated decision-making, including profiling, that produces legal effects concerning an individual or similarly significantly affects them, within the meaning of Article 22 GDPR.

If WEBOVO introduces such processing in the future, this Privacy Policy will be updated before that processing begins to describe the existence of the automated decision-making and the significance and envisaged consequences of such processing for the individual concerned.

Where applicable law requires an appropriate legal basis or a specific exemption for such processing, WEBOVO will only introduce it once that legal basis or exemption is established.

13. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

WEBOVO may process personal data for the following purposes, where relevant:

13.1 Responding to Enquiries

To receive, assess and respond to questions, enquiries and consultation requests.

13.2 Arranging Consultations

To discuss requirements, confirm availability, arrange dates and times, and communicate regarding requested consultations.

13.3 Taking Steps Before an Engagement

To understand a prospective Client's requirements, discuss possible scope, prepare proposals or other engagement information, and take other steps requested before entering into a consulting relationship.

13.4 Providing Services

To provide and administer agreed consulting services.

13.5 Managing Client Relationships

To communicate with Clients and their authorised representatives and manage ongoing professional relationships.

13.6 Operating the Client Portal

Where applicable, to establish, administer, authenticate, support and secure Client Portal access.

13.7 Operating and Protecting the Website

To maintain Website functionality, detect technical problems, protect against misuse, investigate security events, and maintain the integrity of WEBOVO systems.

13.8 Business Administration

To maintain appropriate business, contractual, operational and administrative records.

13.9 Establishing or Defending Legal Rights

To establish, exercise, protect or defend legal rights, respond to disputes, and preserve relevant records where necessary.

13.10 Compliance with Law

To comply with applicable legal, regulatory, tax, accounting, court, law-enforcement or other lawful requirements.

13.11 Preventing Fraud and Misuse

To identify and address suspected fraudulent, abusive, malicious or unauthorised use of the Website, Client Portal or WEBOVO services.

13.12 Marketing Communications

Where WEBOVO sends promotional or business-development communications, to do so in accordance with applicable law and any consent or opt-out requirements that apply.

14. LEGAL BASES FOR PROCESSING

Where the GDPR, UK GDPR, or another law requiring identification of a lawful basis applies, WEBOVO will rely on the legal basis appropriate to the relevant processing activity.

The applicable legal basis may vary depending on the circumstances.

14.1 Steps Requested Before Entering into a Contract

WEBOVO may process personal data where this is necessary to take steps at your request before entering into a contract.

This may apply, for example, when an individual prospective Client:

• requests a consultation;
• asks WEBOVO to assess a proposed engagement;
• requests information necessary to enter into a consulting agreement; or
• communicates regarding the proposed scope of services.

Where you communicate with WEBOVO on behalf of a company or other organisation rather than as the contracting party personally, WEBOVO may instead rely on its legitimate interests in handling and responding to business enquiries.

14.2 Performance of a Contract

Where an individual is personally a party to an agreement with WEBOVO, personal data may be processed where necessary to perform that agreement.

Where WEBOVO contracts with an organisation and processes the personal data of the organisation's employees or representatives, legitimate interests will commonly be the relevant basis rather than contractual necessity in relation to those individuals.

14.3 Legitimate Interests

WEBOVO may process personal data where necessary for legitimate business interests, provided those interests are not overridden by the rights and interests of the affected individual.

Relevant legitimate interests may include:

• responding to B2B enquiries;
• communicating with representatives of prospective and existing Clients;
• administering professional relationships;
• operating and improving the Website;
• maintaining Website and account security;
• protecting WEBOVO systems and information;
• preventing fraud and misuse;
• maintaining appropriate business records;
• managing disputes and legal claims;
• protecting WEBOVO's legal and commercial interests; and
• managing ordinary business operations.

Where required by applicable law, WEBOVO will consider the nature of the information, the reasonable expectations of the individual, the necessity of the processing and the potential impact on the individual before relying on legitimate interests.

14.4 Consent

WEBOVO may rely on your consent where consent is the appropriate legal basis.

This may include, where required by applicable law:

• certain non-essential cookies or similar technologies;
• certain electronic marketing communications; or
• other optional processing for which consent has been specifically requested.

Where processing is based on consent, you may withdraw that consent as described in this Privacy Policy.

14.5 Legal Obligations

WEBOVO may process personal data where necessary to comply with a legal obligation that applies to WEBOVO.

This may include obligations concerning:

• accounting;
• taxation;
• record keeping;
• regulatory requirements;
• legal proceedings;
• court orders; or
• lawful requests from competent authorities.

14.6 Legal Claims and Other Permitted Grounds

Where permitted by applicable law, WEBOVO may process personal data where necessary to establish, exercise or defend legal claims or where another lawful basis or statutory exception applies.

15. SPECIAL CATEGORIES OF PERSONAL DATA

WEBOVO does not generally request special-category or similarly sensitive personal data through its general Website enquiry form.

Because enquiries may concern workplace safety, organisational processes or other business matters, users should take care not to include sensitive personal information unless it is genuinely necessary and there is an appropriate lawful basis for providing it.

Where the GDPR or UK GDPR applies, and WEBOVO is required to process special-category personal data, such processing will require both:

• an appropriate legal basis for processing; and
• an applicable condition for processing special-category data.

Where such information is relevant to a specific consulting engagement, the manner in which it is handled may also be addressed in the relevant engagement documentation.

16. DATA MINIMISATION AND CLIENT RESPONSIBILITY

WEBOVO seeks to limit the personal data it processes to information that is relevant and reasonably necessary for the applicable purpose.

Clients and prospective Clients should similarly avoid providing unnecessary personal data.

Where you provide personal data concerning another individual, you are responsible for ensuring that you have appropriate authority or another lawful basis to provide that information where required by applicable law.

17. ACCURACY OF INFORMATION

WEBOVO takes reasonable steps to maintain accurate information where accuracy is relevant to the purposes for which the information is processed.

You may contact WEBOVO if you believe that personal data relating to you is inaccurate or incomplete.

Where you represent a Client organisation, you should notify WEBOVO of material changes to relevant business contact information where appropriate.

18. COOKIES AND SIMILAR TECHNOLOGIES

The Website may use cookies and similar technologies for purposes such as:

• providing essential Website functionality;
• maintaining security;
• remembering settings or preferences, where applicable;
• supporting Website administration; and
• other purposes described in the WEBOVO Cookie Policy.

The exact technologies used depend on the Website's verified technical configuration.

Where applicable law requires consent before non-essential cookies or similar technologies are stored or accessed, WEBOVO will rely on consent for those technologies.

Technologies that are strictly necessary to provide functionality requested by the user may be treated differently where permitted by applicable law.

For further information, including information about available controls, please refer to the WEBOVO Cookie Policy.

19. COMMUNICATIONS

WEBOVO may use the contact information you provide to communicate with you concerning:

• your enquiry;
• a requested consultation;
• scheduling;
• an existing engagement;
• Client administration;
• service-related information;
• account or security matters; or
• other communications reasonably related to your relationship with WEBOVO.

These communications are not necessarily marketing communications.

20. DIRECT MARKETING

Where WEBOVO sends direct marketing or promotional communications, those communications will be handled in accordance with applicable law.

Depending on the relevant jurisdiction and circumstances, WEBOVO may rely on:

• consent;
• legitimate interests where permitted; or
• another lawful basis recognised by applicable law.

Where required, recipients will be provided with an appropriate method to unsubscribe or object to future direct marketing.

A request to stop marketing communications will not necessarily prevent WEBOVO from sending non-marketing communications that are required or reasonably necessary in connection with:

• an existing engagement;
• a consultation you requested;
• Client Portal security;
• account administration;
• legal obligations; or
• other service-related matters.

21. SERVICE PROVIDERS AND PROCESSORS

WEBOVO may use third-party service providers to support its business operations.

Depending on WEBOVO's operational configuration, these providers may support functions such as:

• Website hosting and infrastructure;
• Website maintenance;
• information technology;
• cybersecurity and system security;
• email and business communications;
• document or data storage;
• Client Portal functionality;
• scheduling;
• professional and administrative support; and
• other services reasonably necessary to operate the Website or provide WEBOVO's services.

WEBOVO does not identify a particular provider in this Privacy Policy unless that provider and its role have been verified.

Where a service provider processes personal data on WEBOVO's behalf, WEBOVO will use appropriate contractual or other safeguards where required by applicable law.

Service providers may process personal data only to the extent permitted by their contractual role, applicable law, or other lawful instructions.

22. DISCLOSURE OF PERSONAL DATA

WEBOVO may disclose personal data where reasonably necessary and legally permitted.

Recipients may include:

22.1 Service Providers

Providers supporting WEBOVO's Website, systems, communications, professional operations or other business functions.

22.2 Professional Advisers

Lawyers, accountants, auditors, insurers, consultants or other professional advisers where disclosure is reasonably necessary.

22.3 Authorities and Legal Recipients

Courts, regulators, law-enforcement authorities, public bodies or other competent recipients where disclosure is required by law, court order, legal process, or another lawful requirement.

WEBOVO may also make a disclosure where reasonably necessary and legally permitted to:

• protect legal rights;
• investigate suspected unlawful activity;
• respond to security incidents;
• prevent fraud or misuse; or
• protect the rights or safety of WEBOVO, its Clients, users or others.

22.4 Corporate Transactions

If WEBOVO or the relevant business is involved in a merger, acquisition, restructuring, financing, sale of assets or similar transaction, relevant personal data may be disclosed to prospective or actual transaction participants and their advisers, subject to appropriate confidentiality and legal protections where required.

22.5 At Your Direction

WEBOVO may disclose information where you or the relevant Client validly instructs or authorises us to do so.

WEBOVO will not treat personal data as freely available merely because it has been provided in a business context.

23. INTERNATIONAL DATA TRANSFERS

The Website may be accessible internationally, and WEBOVO's Clients, service providers or business contacts may be located in different countries.

Personal data will not necessarily be transferred internationally merely because the Website is accessible from another country.

Where WEBOVO transfers personal data to another country and applicable data protection law restricts such transfers, WEBOVO will use an appropriate lawful transfer mechanism where required.

Depending on the applicable legal framework, such mechanisms may include:

• a recognised adequacy decision;
• approved standard contractual safeguards;
• another legally recognised transfer mechanism; or
• a statutory exception available for a particular transfer.

Where legally available and appropriate, individuals may contact WEBOVO for further information concerning safeguards relevant to transfers of their personal data.

24. DATA RETENTION

WEBOVO retains personal data only for as long as reasonably necessary for the purposes for which it was collected or for another legitimate and lawful purpose.

Because different categories of information may be processed for different purposes, a single retention period does not necessarily apply to all personal data.

Relevant retention criteria may include:

• the nature of the information;
• the purpose for which it was collected;
• the duration of a consultation or Client relationship;
• whether an enquiry resulted in an engagement;
• the need to maintain appropriate business records;
• contractual requirements;
• applicable accounting or tax obligations;
• statutory or regulatory retention requirements;
• applicable limitation periods;
• the possibility of a legal dispute;
• security and fraud-prevention requirements; and
• the need to establish, exercise or defend legal claims.

When personal data is no longer reasonably required, WEBOVO will delete, anonymise or otherwise handle it in accordance with applicable legal and operational requirements.

Information may be retained for a longer period where this is required or permitted by law, necessary for legal proceedings, or reasonably required to address a security incident or dispute.

25. INFORMATION SECURITY

WEBOVO takes reasonable technical and organisational measures appropriate to the circumstances to protect personal data against risks such as:

• unauthorised access;
• unauthorised disclosure;
• alteration;
• accidental loss;
• destruction; and
• misuse.

The particular measures used may depend on:

• the nature of the information;
• the relevant systems;
• the nature of the processing;
• the sensitivity of the information; and
• the risks associated with the processing.

No method of transmitting information over the Internet and no electronic storage system can be guaranteed to be completely secure.

Users should therefore take appropriate precautions when sending information electronically and should not send passwords, authentication credentials or unnecessary highly sensitive information through ordinary Website forms or unsecured communications.

26. PERSONAL DATA BREACHES

Where WEBOVO becomes aware of a personal data breach affecting information for which WEBOVO is responsible, it will assess the incident and take steps required by applicable data protection law.

Where applicable law requires notification to a competent supervisory authority or affected individuals, WEBOVO will make the required notification in accordance with the relevant legal requirements.

Where WEBOVO acts as a processor for a Client, incident-related responsibilities may also be governed by the applicable data processing or engagement agreement.

27. YOUR DATA PROTECTION RIGHTS

Depending on the law that applies to you and the circumstances of the processing, you may have some or all of the rights described below.

These rights are not absolute and may be subject to statutory conditions, exemptions or limitations.

27.1 Right of Access

You may have the right to request confirmation as to whether WEBOVO processes personal data relating to you and to obtain access to that data and certain information concerning the processing.

27.2 Right to Rectification

You may have the right to request correction of inaccurate personal data and completion of incomplete information.

27.3 Right to Erasure

In certain circumstances, you may have the right to request deletion of personal data.

This right does not necessarily apply where retention is required or permitted for reasons such as:

• compliance with legal obligations;
• establishment, exercise or defence of legal claims;
• contractual or regulatory record keeping; or
• another lawful ground for continued processing.

27.4 Right to Restriction

You may have the right to request restriction of processing in circumstances provided by applicable law.

27.5 Right to Data Portability

Where applicable legal conditions are satisfied, you may have the right to receive certain personal data in a structured, commonly used and machine-readable format and, where technically feasible, request its transfer to another controller.

27.6 Right to Object

Where WEBOVO relies on legitimate interests, you may have the right to object to processing based on circumstances relating to your particular situation.

WEBOVO will consider an objection in accordance with applicable law.

27.7 Right to Object to Direct Marketing

Where applicable law provides this right, you may object at any time to the processing of your personal data for direct marketing purposes.

27.8 Rights Relating to Consent

Where WEBOVO relies on consent, you may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

27.9 Right to Complain

Where applicable law provides such a right, you may lodge a complaint with the competent data protection or supervisory authority.

28. EXERCISING YOUR RIGHTS

To make a privacy request, contact:

Email: info@webovo.net

Please provide sufficient information to allow WEBOVO to understand and appropriately process your request.

WEBOVO may request additional information where reasonably necessary to:

• verify your identity;
• protect personal data from unauthorised disclosure;
• clarify the scope of your request; or
• determine whether a particular legal right applies.

WEBOVO will respond within the period required by applicable law.

Where legally permitted, WEBOVO may decline or limit requests that are manifestly unfounded, excessive, repetitive, or subject to an applicable statutory exception.

29. WITHDRAWING CONSENT

Where processing is based on your consent, you may withdraw that consent by contacting WEBOVO at:

info@webovo.net

Where a cookie or similar technology is controlled through an available cookie-preference mechanism, consent may also be withdrawn through the relevant preference controls where such functionality is implemented.

Withdrawal applies prospectively and does not invalidate processing lawfully undertaken before withdrawal.

30. RIGHT TO OBJECT TO LEGITIMATE-INTEREST PROCESSING

Where applicable data protection law gives you the right to object to processing based on legitimate interests, you may submit an objection to:

info@webovo.net

WEBOVO will assess the objection in accordance with applicable law, including whether compelling legitimate grounds justify continued processing or whether processing is required for the establishment, exercise or defence of legal claims.

Where the processing concerns direct marketing and applicable law provides an unconditional right to object, WEBOVO will cease the relevant direct-marketing processing as required by law.

31. COMPLAINTS

If you have a concern about how WEBOVO handles personal data, you may first contact:

WEBOVO S.L.
Trading Name: WEBOVO
Company Registration Number: B13922646
Registered Address: Calle de Zurbano 45, 1ª planta, 28010 Madrid, Spain
Country: Spain
Email: info@webovo.net
Website: https://webovo.net/

Where applicable, data protection law gives you the right to complain to a supervisory authority, you may also contact the authority responsible for the relevant jurisdiction. In the case of Spain, the relevant authority is as follows:

Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6
28001 Madrid
Spain
www.aepd.es

The identity of the competent authority may depend on WEBOVO's establishment, your location, the place of the relevant processing, and the law applicable to the particular matter.

Any right to lodge a complaint with a competent authority is unaffected by contacting WEBOVO first.

32. CHILDREN

WEBOVO provides professional consulting services intended primarily for businesses, organisations and professional users.

The Website and Services are not directed primarily at children.

WEBOVO does not intentionally request personal data from children through the Website for ordinary consulting purposes.

If WEBOVO becomes aware that personal data relating to a child has been provided in circumstances where processing is not lawful or appropriate, WEBOVO will take reasonable steps consistent with applicable law.

33. THIRD-PARTY WEBSITES AND SERVICES

The Website may contain links to third-party websites, platforms or services.

Third parties operate under their own terms and privacy practices, and WEBOVO does not control how those third parties process personal data.

Before submitting personal information to a third-party service, users should review the relevant privacy information provided by that third party.

The inclusion of a link does not by itself mean that WEBOVO controls or endorses the third party's privacy practices.

34. CLIENT-SUPPLIED PERSONAL DATA

A Client may provide WEBOVO with personal data concerning employees, contractors, customers, suppliers or other individuals in connection with an engagement.

The Client is responsible for determining whether it is authorised to provide such information and for satisfying its own transparency, legal-basis and other data-protection obligations where applicable.

Where WEBOVO processes such information solely on the Client's behalf and under the Client's instructions, the parties may enter into appropriate data-processing terms where required by applicable law.

WEBOVO may request that Clients minimise or anonymise personal data where identifiable information is not required for the relevant consulting purpose.

35. CONFIDENTIAL BUSINESS INFORMATION

Not all information received by WEBOVO constitutes personal data.

Client enquiries and engagements may also involve confidential commercial, operational, technical or organisational information.

Such information may be subject to:

• contractual confidentiality provisions;
• a separate non-disclosure agreement;
• engagement-specific confidentiality obligations; or
• other applicable legal protections.

This Privacy Policy addresses the protection of personal data and does not replace contractual confidentiality arrangements applying to specific Client engagements.

36. CHANGES IN PURPOSE

Where WEBOVO intends to use personal data for a materially different purpose from the purpose for which it was originally collected, WEBOVO will assess whether the new processing is lawful and compatible with the original purpose.

Where required by applicable law, WEBOVO will provide additional information or obtain consent before beginning the new processing.

37. CHANGES TO THIS PRIVACY POLICY

WEBOVO may update this Privacy Policy from time to time to reflect:

• changes to the Website;
• changes to WEBOVO services or business operations;
• changes to processing activities;
• changes to applicable law or regulatory guidance;
• changes to service providers or technical arrangements; or
• other legal, operational or security developments.

The current version will be made available on the Website.

Where appropriate, material changes may also be communicated through another reasonable method.

The “Last Updated” date at the top of this Privacy Policy indicates when the current version was last revised.

38. INTERNATIONAL USERS

The Website may be accessed from different countries.

The fact that the Website is technically accessible in a particular jurisdiction does not by itself mean that WEBOVO is established, licensed, regulated or specifically targeting services in that jurisdiction.

Privacy rights and obligations may differ depending on:

• where WEBOVO is legally established;
• where an individual is located;
• where processing takes place;
• whether WEBOVO offers services into a particular jurisdiction; and
• the scope of applicable data protection law.

Where a particular data protection law applies to WEBOVO's processing, WEBOVO will process personal data in accordance with the obligations applicable under that law.

39. RELATIONSHIP WITH OTHER WEBOVO DOCUMENTS

This Privacy Policy should be read together with, where applicable:

• the WEBOVO Cookie Policy;
• WEBOVO Terms and Conditions;
• any applicable Legal Notice;
• any applicable Refund and Cancellation Policy;
• a proposal or quotation;
• an engagement letter;
• a statement of work;
• a data processing agreement;
• a confidentiality agreement; and
• other terms specifically agreed for an engagement.

If engagement-specific documentation contains additional privacy or data-processing requirements, those requirements may apply to the relevant engagement in addition to this Privacy Policy.

40. CONTACT DETAILS

As in clause 31, questions concerning cookies, the Cookie Policy, this Privacy Policy, or applicable data-protection rights, or WEBOVO's processing of personal data may be directed to:

WEBOVO
Legal Entity: WEBOVO S.L.
NIF: B13922646
Registered Address: Calle de Zurbano 45, 1ª planta, 28010 Madrid, Spain
Country: SPAIN
Website: https://webovo.net/
Email: info@webovo.net

And where relevant,

Supervisory Authority (Spain):
Agencia Española de Protección de Datos (AEPD)
C/ Jorge Juan, 6
28001 Madrid
Spain
www.aepd.es

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