Privacy Policy

This is a courtesy translation. The Spanish version is the legally binding one and prevails in case of discrepancy.

This Privacy Policy governs the processing of the personal data of users of the TuEmpleadoVirtual platform (hereinafter, “the Platform”). Use of the Platform implies acceptance of the processing conditions described here.

At Trazados Consulting S.L. we are committed to the protection of personal data and comply with the data protection rules in force, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR; in Spanish, RGPD) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (LOPDGDD).

1. Data controller

• Identity: Trazados Consulting S.L.
• Tax ID (NIF): B21814827
• Postal address: Plaza San Juan de la Cruz, 7, 8º puerta 6, 28003 Madrid, España
• Email for exercising rights: info@trazados.com
• General contact email: info@trazados.com

2. Purposes of processing

At Trazados Consulting S.L. we process users’ personal data for the following purposes:

• Account management and authentication: creating, maintaining and managing the user account on the Platform, and verifying identity on login.
• Provision of the service: allowing the user to manage communities of owners, owners, suppliers, incidents, communications and the documentation associated with property administration.
• Subscription and billing management: processing subscription payments and issuing the corresponding invoices.
• Transactional communications: sending notifications essential to the provision of the service (email verification, password recovery, incident alerts, system notifications, etc.).
• User support: handling queries, incidents and complaints raised by the user.
• Service improvement: anonymised statistical analysis of Platform use to improve its features and detect errors.
• Compliance with legal obligations: retention of tax, accounting and billing data in accordance with applicable regulations.

3. Legal basis for processing

The legal basis for processing personal data is, depending on the purpose:

• Performance of a contract (art. 6.1.b GDPR): for account management, provision of the service, and subscription and billing management.
• Compliance with a legal obligation (art. 6.1.c GDPR): for the retention of invoices and accounting documents in accordance with tax and commercial regulations.
• Legitimate interest of the controller (art. 6.1.f GDPR): for anonymised statistical analysis, service improvement and fraud prevention.
• Consent of the data subject (art. 6.1.a GDPR): for sending commercial communications, where the user expressly accepts them. This consent may be withdrawn at any time.

4. Personal data we process

Depending on the relationship with the user, we may process the following data:

• Identification data: full name, company or organisation (property administration firm).
• Contact data: email address and, where applicable, telephone number.
• Access data: encrypted password, login records, IP address.
• Billing data: the data needed to issue invoices (company name, tax ID, registered address).
• Data managed by the user on the Platform: data on owners, suppliers, communities and incidents entered by the firm in the course of its activity, for which the user acts as data controller and Trazados Consulting S.L. as data processor.
• Usage data: anonymous browsing statistics and features used.
• Mobile device data, if the app is used: the notification identifier assigned by the operating system (APNs or FCM token), the platform, the app version and the environment. They are processed for the sole purpose of delivering service alerts, and are deleted on logout, when the app is uninstalled or when the account is closed.
• Diagnostic data: error and performance reports from the mobile app. They are collected without personal data: the user, IP address, headers, cookies and request bodies are removed before sending, and addresses are truncated to discard parameters.

Trazados Consulting S.L. does not collect or process special categories of data (health data, ideology, religion, sexual orientation, etc.).

5. Retention period

Personal data will be kept for as long as the user keeps their account active on the Platform and, once deletion or deactivation of the account has been requested, for the legally established periods needed to address possible liabilities arising from the processing, in particular:

• Tax and accounting data: 6 years (art. 30 of the Spanish Commercial Code).
• Data subject to tax obligations: 4 years (General Tax Act).
• Anonymised browsing data: indefinitely, as it does not allow the user to be identified.

6. Recipients of the data

Personal data will not be disclosed to third parties, except where legally required. However, to provide the service, Trazados Consulting S.L. uses providers that act as data processors and are duly bound by contract in accordance with article 28 of the GDPR:

• Amazon Web Services (AWS): hosting infrastructure and cloud services (EU region — Frankfurt).
• Artificial intelligence providers for the virtual assistant features, processing strictly the data needed to generate the requested responses.
• Email and transactional messaging providers for sending service notifications.
• Anonymised analytics tools for usage statistics.
• Apple Inc. and Google LLC, solely for delivering notifications to mobile devices through their APNs and FCM services. They receive the device identifier and the text of the alert, which is worded so as not to include names, phone numbers or the content of communications.
• Error-reporting provider for the mobile app, which receives the already anonymised diagnostic data described in section 4.

Some of these providers may involve international transfers of data outside the European Economic Area (EEA). In all cases, such transfers are covered by the appropriate safeguards provided for by the GDPR, such as the Standard Contractual Clauses approved by the European Commission.

7. User rights

As the holder of the personal data, the user has the right to:

• Access: obtain confirmation of whether their data is being processed and, if so, access it.
• Rectification: request the correction of inaccurate or incomplete data.
• Erasure (“right to be forgotten”): request the deletion of data when it is no longer necessary.
• Restriction of processing: request the restriction of the processing of their data in certain circumstances.
• Portability: receive the data in a structured, commonly used and machine-readable format, or request its transmission to another controller.
• Objection: object to the processing of their data in certain circumstances.
• Not to be subject to automated decisions: including profiling, that produce legal effects or significantly affect them.
• Withdraw consent: at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

The user may exercise these rights by sending a written request, attaching a copy of a document proving their identity, to the postal address given or by email to info@trazados.com.

To request the closure of the account there are also two direct routes: from the mobile app, under More → Settings → Request account closure, and from the website at tuempleadovirtual.com/en/delete-account, which details which data is deleted and which is kept.

Likewise, the user has the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), located at calle Jorge Juan 6, 28001 Madrid, or through its electronic office at www.aepd.es, if they consider that the processing does not comply with the regulations in force.

8. Security measures

Trazados Consulting S.L. has adopted the technical and organisational measures necessary to guarantee the security of personal data and prevent its alteration, loss, unauthorised processing or access, taking into account the state of the art, the nature of the data stored and the risks to which it is exposed. These measures include: encryption in transit (TLS), encrypted password storage, isolation of data per firm (multi-tenant architecture), role-based access controls, regular backups and logging of access activity.

9. Cookies

The Platform uses technical cookies strictly necessary for its operation (session maintenance, storage of user preferences). These cookies do not require the user’s consent as they are exempt under article 22.2 of Law 34/2002 (LSSI-CE).

Should analytics or third-party cookies requiring consent be used, the user will be informed and their authorisation will be expressly requested at the appropriate time.

10. Amendments

Trazados Consulting S.L. reserves the right to amend this Privacy Policy to adapt it to legislative or case-law developments, as well as to industry practices. In such cases, the changes introduced will be announced on the Platform with reasonable notice before they are put into practice.