Important information and who we are

m247.com/es is a website owned by M247 Iberia, S.L., and. M247 is a trade name for M247 Iberia, S.L., Metronet (UK) Limited, M247 Ltd, M247 Europa S. R. L. and Venus Business Communications Limited (“we”).

In Spain we have a subsidiary of the group called M247 Iberia, S.L., which is a limited liability company with the Corporate Tax Code number B01883727, and registered office in Malaga, Plaza de la Solidaridad, number 12, 5th floor, P.C. 29006. It was incorporated by means of a public deed granted on 31 August 2020 before the notary public of Malaga Mr José Sánchez Aguilera, under his protocol number 1836, and duly registered in the Malaga Companies Registry on page MA-156979, Volume 5966, Folio 16, entry one.

We are committed to protecting and respecting your privacy and personal data.

This policy (together with our Terms of Use (see our website) and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide us with, will be processed by us.

Please read the following to understand our views and practices regarding your personal data and how we will process them.

We have appointed a Data Protection Officer, who is responsible for overseeing certain matters relating to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details below.

Contact Details

Our details are:

Legal entity’s full name: M247 Iberia, S.L.

Email address: info@m247.es

If you feel that we have not fulfilled any of our legal obligations regarding your personal data, you should know that you have the right to file a complaint at any time with the Spanish Data Protection Agency (https://www.aepd.es/es). However, before approaching the competent authorities, we would like to have the opportunity to address your concerns so please contact us as soon as possible.

 

Changes to the privacy notice and your duty to inform us of changes

Personal data protection legislation in Spain results from the entry into force on 25 May 2018 of the new General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the Guarantee of Digital Rights. This privacy policy aims to fully comply with the new regulations.

It is important that the personal details we hold about you is accurate and up to date. Please keep us informed if your personal details change during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on these links or enabling connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we invite you to read the privacy notice of each website you visit.

Information we may collect from you

Personal details or personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different types of personal data about you in the following ways:

  • Information provided to us by you. You can provide us with information about yourself by filling out the forms on our site m247.com/es or contacting us by telephone, email or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, participate in discussion forums on our site, enter a contest, promotion or survey, and when you report a problem with our site. The information you provide to us may include identifying information, such as your name, your personal identification number (NIF) and your customer number. Contact information such as address, email address and phone number, financial data such as credit card and financial information.
  • Information we collect about you. With reference to each of your visits to our website, we may automatically collect the following information:
  • technical information, such as the Internet Protocol (IP) used to connect your computer to the Internet, your login information, browser type and version, time zone settings, browser type and version plug-in, operating system and platform;
  • information about your visit, including the Uniform Resource Locator (URL) clickstream, through and from our website (including date and time); the products you viewed or searched for; page response times; download errors; the length of visits to certain pages; information about interaction with the page (such as scrolling, mouse clicks and off); and the methods used to browse off the page and any telephone number you use to call our customer service number.
  • profile information such as username and password, purchases/order, interests, preferences, comments and survey responses.
  • usage information about how you use the website, products and services.

 

  • Information we receive from other sources. We may receive information about you if you use any of the other websites we operate (if any) or other services we offer. In this case we will inform you when we collect such data which may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analysis providers, information search providers, credit rating agencies) and may receive information about you from them.

We do not collect any Special Personal Data Categories about you, unless it is part of our contract with you (this includes details about your race or ethnic group, religious or philosophical beliefs, sex life, sexual orientation, political opinions, business, union membership, health and genetic information and biometric data). Nor do we collect any information about criminal convictions and offences.

If you do not provide personal data

Where we need to collect personal data by law, or under the terms of the contract we have with you and you do not provide the data requested, we may not be able to fulfil the contract we have, or are trying to fulfil with you (for example, providing the goods or services). In this case, we will be forced to cancel the product or service you have with us, but we will notify you in time if this is the case.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide a good experience when browsing our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that is stored in your browser or on your computer’s hard drive if you agree. Cookies contain information that is transferred to your computer’s hard drive.

You may block cookies by activating the setting on your browser that allows you to refuse the installation of some or all cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We use the following cookies:

  • Essential Cookies. These are the cookies that are required for our website to operate. These include, for example, cookies that allow you to log into secure areas of our website.
  • Analytical/Performance Cookies. They allow us to recognise and count the number of visitors and see how visitors move around our website, when they are using it. This helps us to improve the way our website works, for example, to ensure that users find what they are looking for easily. This is statistical information and does not identify any individual.
  • Functionality Cookies. These are used to recognise you when you return to our website. This allows us to personalise our content for you, greet you by your name and remember your preferences (e.g., language or region selection).
  • Guidance Cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

Please note that some third parties (including, for example, advertising networks and external service providers such as web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or guidance cookies. All information collected by such third parties is governed by their own privacy/cookie policy.

Our use of your personal data

We will only use your personal data when the law allows us to do so. Most of the time, we will use your personal data in the following circumstances:

  • When we have to comply with the contract we are about to sign or have signed with you.
  • Where required for our legitimate interests and where your interests and fundamental rights are not jeopardised by such interests.
  • When required to comply with a legal or regulatory obligation.

In general, because the personal data we collect and the process is based on the contract whereby we provide our services/products, we do not recognise consent as a legal basis for processing your personal data beyond the third party that sends you direct marketing communications via email or text message. You have the right to withdraw your consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways in which we intend to use your personal data, and the legal grounds on which we are allowed to do so. We have also identified our legitimate interests where appropriate.

Please note that we may process your personal data for more than one legal purpose depending on the specific purpose for which we are using your data.

Goal/Activity Type of data Legal Basis for Processing Legitimate Interest Basis
To register as a new customer (a) Identity (b) Contact Contract compliance with you
To process and deliver your order, including:(a) Managing payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity (b) Contact

(c) Financial

(d) Transaction

 

(a) The performance of a contract with you

(b) Required for our legitimate interests (to recover outstanding debts)

To manage our relationship with you, which will include:(a) Notifying amendments to our terms or privacy policy

(b) Asking when leaving a comment or taking a survey

(a) Identity (without your personal identification number) (b) Contact

(c) Profile

 

(a) The performance of a contract with you

(b) Required to meet a legal obligation of yours

(c) Required for our legitimate interests (to keep our records up to date and to study how customers use our products/services)

To allow you to participate in a draw, contest or complete a survey (a) Identity (your identification number is used strictly for the obligations of the fiscal year and only for the winners of the various prize draws or competitions) (b) Contact

(c) Profile

(d) The use of

 

(a) The performance of a contract with you (b) Required for our legitimate interests (the study of how customers use our products/services, to develop and grow our business)
To manage and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting) (a) Identity (without the personal identification number) (b) Contact

(c) Technique

(a) Required for our legitimate interests (to operate our business, to provide management and IT services, network security, to prevent fraud and in the context of a corporate reorganisation or group restructuring)

(b) Required to meet a legal obligation

To deliver relevant website and ad content, and measure or understand the effectiveness of the advertising that is of use to you. (a) Identity (without the personal identification number) (b) Contact

(c) Profile

(d) Use

(e) Technique

It is necessary for our legitimate interests (the study of how customers use our products/services, to develop, to grow our business and to inform our marketing strategy)
To use data analysis to improve our website, products and/or services, marketing, customer relations and experiences (a) Technique

(b) Use

It is necessary for our legitimate interests (to define the types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations about products or services that may be of interest to you (a) Identity (without the personal identification number) (b) Contact

(c) Technique

(d) Use

(e) Profile

It is necessary for our legitimate interests (to develop our products/services and for our business to grow)
To provide a live chat service (a) Identity (without a personal identification number)

(b) Contact

Your consent to allow us to engage with you

 

Marketing

We strive to provide you with choices regarding certain uses of personal data, particularly in relation to marketing and advertising.

We may use your identity (without your personal identification number), contact, technique, use of a data profile to have a formed opinion about what we think you want or need, or what may be of interest to you. This is like saying which products, services and offers may be relevant to you (we call this marketing).

You will receive our marketing communications if you have purchased our goods or services or if you provided us with your information when you entered a contest or registered for a promotion or if you have chosen any other method for marketing purposes, in each case, unless you have chosen not to receive marketing.

For marketing purposes, we will only process your name and email address as personal data and we will also use your order/purchase of services/products information.

Third Party Marketing

Your express consent will be obtained before sharing your personal information with any company outside our group of companies for marketing purposes.

Disclaimer

You may ask us to stop sending you marketing messages at any time by registering on the website and checking or unchecking the appropriate boxes to adjust your marketing preferences or by following the opt-out links in any marketing message we send you or by contacting us at any time at info@m247.es .

Change of purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis allowing us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where necessary or permitted by law.

Disclosure of your personal data

We may need to share your personal data with the parties described below for the purposes set out in the table above:

  1. i) Third parties to whom we decide to sell, transfer or combine parts of our business or assets. Alternatively, we may try to acquire other companies or merge with them. If a change occurs in our business, then the new owners may use your personal information in the same manner as set forth in this privacy notice.

We will require all third parties to respect the security of your personal data and to process them pursuant to Law. We will not allow our third-party service providers to use your personal data for their own purposes and will only allow them to process your personal data for specific purposes and in accordance with our instructions.

  1. ii) If we receive a claim from a third party for misuse of the service in any unlawful way (for example, where there is an alleged breach of copyright). If we receive a complaint, we may use your IP address to notify you. Unless required to do so by law, we will not disclose your personal information to the requesting party.

iii) We may also need to withhold certain information about your use of Internet services in compliance with the law. We will only disclose this information when we are legally required to do so.

Data Security

We have put in place appropriate security measures to protect your personal data from accidental loss, unauthorised use or access, alteration or disclosure. In addition, we will limit access to your personal information to employees, agents, contractors and other third parties who need to know. They will only process your personal data on our instructions and will be bound by their duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breaches and will notify you and any competing regulator of a breach where we are legally required to do so.

Withholding of data

How long will my personal data be used?

We will only withhold your personal data for the time required to fulfil the purposes for which they were collected, including meeting any legal, accounting, or reporting requirements.

In determining the withholding period of personal data, we will take into account the amount, nature and sensitivity of the personal data, the potential risk of harm from an unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether those purposes can be achieved through other means, and applicable legal requirements.

In some circumstances, you may request that we delete your data: see below for more information.

In some circumstances, you may choose to have your personal information made anonymous (so that it cannot be associated with you) for statistical or research purposes, in which case we may use this information unlimitedly without notice to you.

Your legal rights

You have rights under the data protection regulations with regard to your personal data. These rights are listed below:

  • Access to your personal data.
  • Rectification of your personal data.
  • Deletion of your personal data.
  • Limitation of processing your personal data.
  • Opposition and Suspension of the processing.
  • Portability of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the above rights, you may contact us in writing at any time during normal business hours by e-mail to info@m247.es or by registered letter to the following address: Malaga, Plaza de la Solidaridad, number 12, 5th floor, P.C. 29006.

Gratuitousness

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge you a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, complying with your request may be refused in these circumstances.

What we need from you

We may need to ask you for specific information to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data are not disclosed to anyone who is not entitled to receive them. We may also contact you to ask for more information regarding your request to expedite our response.

Response time limit

We will attempt to respond to all legitimate requests within 30 (thirty) days of the request. Sometimes it may take us more than 30 (thirty) days if your request is particularly complex or if multiple requests have been received. In this case, we will notify you and keep you updated.

LEGAL BASIS

Legitimate interest: our business’ interest in carrying out and managing our business in order to provide the best service/product and the best and most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where there is a conflict of interest with yours (unless we have your consent or are required or allowed by law). Contact us for more information on how we assess our legitimate interests in a situation of conflict of interest with yours in relation to specific activities.

Contract compliance: your data will be processed when required to perform a contract that you are a party to or when taking action at your request before entering into such a contract is required.

Compliance with a legal or regulatory obligation: your personal data will be processed when necessary to comply with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal third parties

Other companies in our Group, acting as co-data controllers or processors.

External third parties

  • Services providers who act as our sub-processors in order to assist us in providing our services.
  • Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors and insurance companies offering consulting, banking, legal, insurance and accounting services.
  • Government authorities or other government entities that request personal data from our customers, but limited to tax authorities, customs. The Spanish Internet Domain Name Registry (.es of the area) and other domain name registrars.

YOUR LEGAL RIGHTS

You have the right to:

access your personal data (commonly known as “data access request”). This allows you to receive a copy of the data we have about you and to check that we are processing it legally.

rectification of the personal data we have about you. This allows you to correct any incomplete or inaccurate information we hold about you, although we may need to verify the accuracy of new information you provide.

delete your personal data. This allows you to ask us to delete or remove your personal data, when there is no good reason to continue with the process. You also have the right to ask us to delete or remove your personal data when you have exercised your right to object to its processing (see below), when we have processed your information illegally or when we are obliged to delete your personal data in order to comply with local legislation. Note, however, that we may not always be able to comply with your request for deletion for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

limit the processing of your personal data (or those of a third party) when we have a legitimate interest and there is something about your particular situation that makes you want to object to its processing in this territory because you feel it has an impact on your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, it can be shown that we have legitimate reasons for processing your information restricting your rights and freedoms.

opposition and suspension of the processing of your personal data. This allows you to ask us to stop processing your personal data in the following cases: (a) if you want us to require the information; (b) if our use of the data is unlawful, but you do not want us to delete it; (c) if you need us to store the data, even if we no longer require it because you need it to establish, exercise or defend yourself against legal claims; or (d) if you have objected to our use of your data, but we need to verify whether there are legitimate grounds for us using them.

portability of your personal data to you or a third party. We will provide you, or a third party of your choice, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to the automated information to which you initially consented to its use or where such information was not used to enter into the contract with you.

Withdrawal consent at any time when we rely on your consent to process your personal data. However, this will not affect the legality of any processing carried out before you withdraw your consent. If you withdraw your consent, it may not be possible to provide you with certain products or services. We will advise you if this is the case when you withdraw your consent.