This website is the responsibility of VN CODE LLC (hereinafter "SURICATU"), with registered office at 651 N Broad St, Suite 201, Middletown, New Castle 19709, Delaware. SURICATU declares to respect the Spanish and European legislation in force regarding Personal Data Protection, specifically, the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, and in accordance with the state of technology, the nature of the data and the risks to which they are exposed, SURICATU declares to implement appropriate technical and organizational measures to ensure the confidentiality and privacy of personal data collected through this website, as well as the integrity, availability and security of the same, taking the necessary actions to prevent any alteration, loss, unauthorized access or fraudulent use of the data processed.
SURICATU guarantees that the User's personal data are processed in a lawful, fair and transparent manner, and that they have been collected with the consent of the User after explicit information on the purpose of the processing expressly indicated in this Privacy Policy or on any other legitimate legal basis established by law. For example, the reception of queries from the Users at our postal address or e-mail address, derived from the legal obligation to offer the Users direct and effective means of communication with SURICATU.
SURICATU will not process or share personal data of the Users except as permitted by current regulations, at the request of competent authorities and when it has the express and previously informed consent of the User.
SURICATU will not use the personal data of Users for purposes other than those previously informed prior to the submission of data by the User.
Personal information refers to any information that relates to an identified or identifiable natural person, directly or indirectly, (name, identification number, location data or factors specific to that person's physical, psychological, genetic, mental, economic, cultural or social identity, geographic location, financial information and bank account numbers, as well as unique identifiers, such as ID numbers, IP, MAC, social security, driver's license, etc).
Specifically protected personal information is information related to race or ethnicity, political opinions, religious beliefs, membership in employee associations, physical or mental health, additional medical information, including biometric and genetic data or sexual preferences, background or convictions.
How do we use personal information?
Transparency and information on personal data protection.
We want to make our privacy practices clear so that you can make informed decisions about the use you want to allow of your personal information by SURICATU. The operations, managements and technical procedures that are carried out in an automated or non-automated way and that make possible the collection, registration, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of enabling access or interconnection, limitation, suppression or destruction on personal data or sets of personal data have the consideration of personal data processing. Through this website we collect, use, disclose, transfer and store personal information when necessary to provide our services or to fulfill our operational and business purposes, as described in this Privacy Policy.
We will always require your prior consent to the processing of your personal data for one or more specific purposes that will be informed prior to the submission of your data. Minimization. We only require from users the data strictly necessary in relation to the purposes of data processing.
We keep the data for the time necessary in relation to the purpose of the processing. We inform in each case of the retention period and, in cases where the purpose is a periodic service (for example, a subscription) we review and update the personal databases by deleting inactive records and those in which the User decides to unsubscribe.
We apply appropriate technical and organizational security measures for the processing of personal data ensuring confidentiality and minimizing the risk of unauthorized access or misuse of personal data of users by third parties.
Type of personal information we collect.
We collect personal information from you through:
Email address
The contact telephone
The postal address of the company
Own and third party cookies
Through the aforementioned ways we can collect the following information:
First and last name;
E-mail address;
Any opinion or comment that you freely decide to provide us;
Any other information and/or file that you freely decide to transfer to us.
Your commitment: the veracity of the data you provide us
The User declares that the personal data provided to SURICATU in any part of the use of this web are truthful. As User you must know that you are the only responsible for any damage or harm, direct or indirect, that could be caused to SURICATU as responsible for this web site or to a third party, if you fill in any form with false data or data of third parties causing deceit, damage or harm. In order to keep your data accurate and up to date, we kindly ask the User to inform us of any variation that may occur in the data provided.
It is forbidden by SURICATU the sending of personal data through this web site by Users under 13 years of age. In the event that SURICATU detects Users who may be under the indicated age, it will not process their data and therefore will not respond to the requests.
SURICATU reserves the right to request a copy of your ID card or equivalent document that accredits its legitimacy in the event of having well-founded suspicions about the User's minority of age.
SURICATU informs that all personal data provided by the User through this web site will be incorporated and processed by SURICATU as data controller with the following purposes:
Legal Obligations:
We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection or investigation of a crime, prevention of loss or fraud or to meet internal and external audit requirements, our information security objectives, crime prevention, which may involve processing: (a) under applicable law, which may include laws outside the User's country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies and other public and governmental authorities, which may include authorities outside the User's country of residence; (c) and to protect our rights, privacy, safety or property, or those of others.
Prior to sending any request or information through any form on this website, you must expressly agree to have read this Privacy Policy, which for legal purposes implies that you have given unequivocal, express, free, specific and informed consent to the processing of your personal data for the purposes indicated.
The aforementioned express consent implies the authorization of the treatment of your data by SURICATU in the terms established in this Privacy Policy, as well as by the co-responsible and responsible for the treatment with whom SURICATU maintains a contractual and compliance control relationship.
In some cases SURICATU uses third party tools and services for the management of this web. Some of these services may be owned by third parties resident outside the European Union (Google, WordPress, etc). SURICATU endeavours to use secure tools whose servers are preferably located in Spain, or failing that, in a member state of the European Union, or which comply with European legislation in accordance with the guidelines and recommendations of the Spanish Data Protection Agency, the European Commission and the Community agreements of reference in matters of international transfer of data, including obtaining certification on the Privacy Shield list.
Most of these third parties claim to comply with European data protection regulations and even have their servers and/or headquarters in Europe. However, in the event that the international transfer of data is necessary, the acceptance of this Privacy Policy means that you as User expressly consent to such transfer.
In order to protect the personal data of web Users, SURICATU ensures by itself and controls its processors, in the implementation of technical and organizational measures appropriate to the state of the art to protect personal data, taking into account the scope, context and purposes of processing, as well as the risks of varying likelihood and severity to the rights and freedoms of data subjects, seeking to be able to ensure the confidentiality, integrity, availability and resilience of the systems and services of the treatment.
In particular, SURICATU has implemented Protocol of encryption and authentication of the connection (TLS 1.2 (a strong procolol), ECDHE_RSA with P-256 (a strong key exchange), and AES_128_GCM (a strong cipher)) which guarantees that the personal data consulted by us are transmitted to our servers through a secure SSL connection ("Secure-Socket-Layer"), in order to protect them from third parties.
Our information security policies and procedures are regularly reviewed and updated to meet our business needs, technological changes and regulatory requirements.
We implement technical and organizational measures to store and transfer information securely in order to protect against accidental loss or attack, as well as unauthorized access, use, destruction or disclosure.
We have a privacy and security risk assessment strategy, as well as a disaster recovery and business continuity plan designed to safeguard the continuity of our services and to protect our staff and our data.
We have a privacy and security risk assessment strategy, as well as a disaster recovery and business continuity plan designed to safeguard the continuity of our services and to protect our staff and our data.
We enforce appropriate restrictions on access to personal information
We apply appropriate restrictions on access to personal information.
We regularly train and sensitize our staff on security and personal data protection and require our suppliers in charge of the processing of the accreditation of the security controls appropriate to the processing of personal data that, in each case, they carry out.
We require our suppliers in charge of the processing of personal data to accredit the accreditation of the security controls appropriate to the processing of personal data that, in each case, they carry out.
We require our employees and contractors to be continually trained in the area of information security, as well as in other relevant areas, as they have access to personal information and other sensitive data.
SURICATU states to be able to act quickly and effectively to restore availability and access to personal data in case of identifying the production of a physical or technical incident, maintaining for this purpose an internal Incident log, an incident response plan, as well as the necessary management activities and control of backups that ensure the recovery of information in the event of a possible security incident.
SURICATU declares to store encrypted personal data of Users in secure servers, protected against the most common types of attacks and located in Spain, Europe, or in the case of storage outside Europe, after verification of compliance with European agreements (Privacy Shield).
In the event of a breach of security of personal data, unless such security breach is unlikely to constitute a risk to the rights and freedoms of natural persons, SURICATU will notify the Spanish Data Protection Agency within 72 hours of becoming aware of the incident, describing the nature of the breach, the possible consequences that may arise and the measures taken or proposed to remedy the security breach; and if possible, the categories and approximate number of data subjects and data affected will be made known.
SURICATU will also notify data subjects, as soon as possible, when the breach of security of personal data is likely to result in a high risk to the rights and freedoms of individuals, describing the possible consequences that could result and the measures taken or proposed to be taken to remedy the security breach.
At any time the User may withdraw his consent and/or exercise his rights of access, rectification, suppression, limitation, opposition and portability provided for in the European regulations on personal data protection, by sending a letter to SURICATU Avenida Navarro Reverter, 6 - PISO 2 C, Valencia, 46004 or by e-mail to [email protected].
In this case, the User must indicate the right he/she wishes to exercise and attach a copy of his/her ID card or any other valid identification documentation that legitimates him/her to do so, including the one that allows his/her electronic identification.
The right of access entitles the User to obtain information on what personal data is being processed, the purpose of the processing, the categories of data processed, the storage period or criteria, the recipients or categories of recipients; if profiling is carried out the significant information of the logic applied and the consequences of the processing envisaged; the exercise of the rights of rectification or erasure of personal data and of the limitation or opposition to the processing and the right to submit a complaint to the Supervisory Authority. To exercise it, the User does not need to issue justification, unless he/she has exercised it in the last six months.
In the event of exercising your right of access, SURICATU is legally obliged to resolve on the request for access within a maximum period of one month from receipt of the request, providing a copy of the personal data subject to processing or allowing remote access to the same. SURICATU will also provide any additional copy requested by the interested party, upon payment of the fee generated by the administrative costs of issuance.
SURICATU may refuse access and invoke, where appropriate, the protection of the Data Protection Agency on the grounds that such access has been exercised within the previous six months, or because it is provided for or prevented by a national or Community regulation.
The right of rectification entitles the User to demand SURICATU to rectify the data which he/she understands to be inaccurate or incomplete. To do so, the User must indicate to which data he/she refers and the correction to be made, providing documentation that justifies it. In this case, SURICATU will have to carry out the rectification as soon as possible and, in any case, within one month from the reception of the request. This period may be extended for a further two months if necessary, taking into account the complexity and number of requests. SURICATU shall inform the interested party of the extension within the first month from the request.
The right of erasure (or "right to be forgotten") means that the User has the right to have data erased when the processing is unlawful, the data subject has withdrawn consent or exercised the right to object and no other legitimate grounds for the processing prevail; they are no longer necessary in relation to the purposes for which they were collected or processed; or they must be erased in order to comply with a legal obligation of SURICATU.
The data subject shall not be entitled to have his/her data deleted by SURICATU when the processing is necessary to exercise the right to freedom of expression and information; to comply with a SURICATU legal obligation; for the formulation, exercise or defence of claims; in the public interest based on the legislation in force for reasons of public health or for historical, statistical or scientific research purposes.
SURICATU will respond to your request as soon as possible and, in any case, within one month of receipt of your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. SURICATU shall inform the interested party of the extension within the first month from the request.
The right of opposition means that the User has the right not to have the processing of his personal data carried out or to cease processing in cases where the processing is based on direct marketing, profiling; the interests or the rights and freedoms of the data subject, especially if he is a child, prevail over the legitimate interest of SURICATU or third parties; historical, statistical or scientific research, unless the processing is necessary for reasons of public interest.
SURICATU will respond to your request as soon as possible and in any case within one month of receipt of your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. SURICATU shall inform the interested party of the extension within the first month from the request.
The right to limitation of processing means that the User has the right to decide which personal data he/she does not want to be processed again in the future, being able to exercise this right when he/she has previously contested the accuracy of the same; when the processing is unlawful and instead of exercising the erasure of the same he/she decides to limit it for future processing; or when he/she considers that SURICATU no longer needs the personal data for the authorized purposes of processing, but instead, the User needs it for the formulation, exercise or defense of claims.
In case of limitation of processing, the restriction may be lifted if there is consent of the data subject; possibility that the processing affects the protection of the rights of another natural or legal person; judicial proceedings that justify it; or there is an important reason of public interest based on the legislation in force.
SURICATU will respond to your request as soon as possible and, in any case, within one month of receipt of your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. SURICATU shall inform the interested party of the extension within the first month from the request.
The right to portability means that the User has the right to receive the personal data provided to SURICATU or to have SURICATU transmit them to another controller, in a structured format of common use and mechanical reading, provided that, the processing is carried out by automated means and the processing is based on the consent that one day the User provided for one or more specific purposes, or for the execution of a contract to which he/she was a party.
The right to portability shall not apply when the transmission is technically impossible; nor when it may adversely affect the rights and freedoms of third parties; nor when the processing has a public interest mission based on the legislation in force.
SURICATU will respond to your request as soon as possible and, in any case, within one month of receipt of your request. This period may be extended by a further two months if necessary, taking into account the complexity and number of requests. SURICATU shall inform the interested party of the extension within the first month from the request.
Treatment managers
We share personal information with third parties for the purpose of providing services or conducting business operations on the terms described in this Privacy Policy or where we believe it is permitted or required by law. What we share with third parties is generally non-personal, anonymous or statistical data. When we share personal information, we do so in accordance with privacy and data security requirements, as well as in accordance with this Privacy Policy.
SURICATU informs the User that his or her personal data may be transferred to:
If SURICATU is required by the competent authorities to respond to legal requirements, criminal investigation of possible illegal activity or claims that a content infringes the rights of third parties or to protect the rights, property or security of third parties, it may communicate to the competent authorities personal information of the Users.
If the rights over the web were to be transferred to another entity, SURICATU undertakes to agree the subrogation and commitment of the new managing entity responsible for the treatment of personal data for the continuation of this Privacy Policy, warning the commitment that if the personal information is going to be used in a way contrary to this policy, the User must be previously notified.
In SURICATU we use cookies (small information files that are downloaded in the terminal equipment of a User when accessing a web, with the purpose of storing data that can be updated and recovered by the person responsible for its installation) to carry out certain functions that are considered essential for the correct operation and visualization of the web site and, in some cases, to store and manage the User's preferences on the language of the web and to collect analytical and usage data.
To obtain these analyses, SURICATU may store certain information in server logs automatically through the use of cookies that collect usage and navigation data relating to the User's use of www.suricatu.com. These records usually include information such as, for example, the type of browser, browser language, date and time of access request, URL, model of equipment or device, operating system version, unique identifiers (IP) and data on the mobile network used in accessing and browsing this web.
SURICATU may use cookies that record IP addresses in the access and navigation to analyze and measure the access and time spent on the different pages of this website and draw conclusions about the trend of web traffic.
It is convenient for the User to know that we use Internet tools and platforms that install cookies that do not depend on SURICATU, so it is possible that the owners of such tools use such data for other uses for which SURICATU is not responsible.
The personal data provided will be kept as long as the User does not request their deletion for the purpose of keeping him/her informed about the actions promoted by SURICATU and as long as they are adequate, relevant and limited to what is necessary for the purposes for which they are processed in accordance with this Privacy Policy.
SURICATU does not authorize the copying, reproduction or reuse of this privacy policy that has been specifically analyzed to respond to the obligations inherent to this website.
SURICATU is based in Spain, so the content of this Privacy Policy has been drafted under Spanish law and applicable regulations of the European Union.
The User accepts that claims or complaints against SURICATU arising from or related to the use of this web site and more specifically with the treatment of his personal data will be resolved by the court of competent jurisdiction located in Valencia. If SURICATU should have to make any kind of claim, it will do so before the competent court of the User's domicile or in Valencia in the case of legal persons or non-consumer professionals.
If the User accesses this site from a location outside Spain, he/she is responsible for complying with all local and international laws applicable to him/her.
SURICATU may modify this Privacy Policy at any time, taking into account the evolution of this website and the contents offered therein, if deemed necessary, either for legal reasons, for technical reasons, or due to changes in the nature or layout of the website, without any obligation to notify or inform the user of such changes, being understood as sufficient publication on the website itself.
Any modification shall have effect with respect to Users who use this website after such modification. Continued use of this site after the publication of any changes shall be deemed acceptance of the same. That is why, at the end of these Terms of Use will always be published the last date of its update, so that the changes introduced will be effective from that date.
In the event that the user does not agree with the updates to our Privacy Policy, you may waive them by not entering your personal data in the contact forms on the website or by exercising your right of opposition, cancellation or deletion in the terms set forth in the Exercise of rights section of this Privacy Policy.