Privacy Policy

This Privacy Policy is provided in accordance with EU Regulation 2016/679 (GDPR) and Organic Law 3/2018 of December 5 on the Protection of Personal Data and the Guarantee of Digital Rights, regarding the processing of personal data provided by data subjects while accessing and using the website (hereinafter, the “Web Application”) that DOMOBLOCK makes available to data subjects (hereinafter, “Users” or “Data Subjects”), and during the services provided by DOMOBLOCK.


1.- Who is the data controller?
The data controller for your personal data is DOMOBLOCK REAL ESTATE INVESTMENT, S.L. (hereinafter, “DOMOBLOCK”), with Tax ID No. B-16865487, and located at Calle Presen Sáez de Descatllar 2, 3rd Floor, Door 12, 46018 – Valencia. Contact email: info@domoblock.io


‍2.- Recommendations
Please read the following recommendations carefully and follow them
:- Keep your device equipped with properly updated antivirus software to protect against malware and spyware applications that could compromise your Internet browsing and the information stored on your device.
- Read and review this Privacy Policy and all legal texts made available by DOMOBLOCK on the Web Application.
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‍3.- Information regarding DOMOBLOCK’s processing of personal data through the Web Application:
(a) DOMOBLOCK may process the following types of personal data provided, if applicable, by the User:
(i) Identification data.
(ii) Contact information.
(iii) Financial information.
(iv) Information regarding investment knowledge and experience.
(v) Information regarding the origin and source of investment funds and assets.

(b) Furthermore, in order to provide Users with transparency regarding the status of investments published on the Web Application, DOMOBLOCK may make available to Users personal data included in documents obtained from public sources or records, including documents obtained from the property registry, such as simple notes. In this regard, DOMOBLOCK will ensure compliance with the data protection principles of lawfulness, fairness, data minimization, and purpose limitation.


‍4.- How Does DOMOBLOCK Process Personal Data? 
DOMOBLOCK will process Users’ personal data as follows:
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(i) Provision of services through the Web Application:
(a) Purpose: To provide services to Users, including investment services.
(b) Categories of data processed:
(i) Identifying data (first and last names, national ID or tax ID number, passport number, or similar).
(ii) Contact information (including email address, phone number, and mailing address). 
(iii) Financial and banking data (including bank account information and payment details).
(iv) Data regarding investment knowledge and experience.
(v) Data regarding the origin and source of investment funds and assets.
(vi) Login credentials (password and username).

(c) Categories of Data Subjects: Registered users who use the Application.

(d) Method of collection: directly through the user’s registration. 

(e) Legal basis: processing is necessary for the performance of a contract to which the Data Subject is a party, and the user’s consent.

(f) Retention period: for the duration of the provision of services; after termination, your data may be blocked for the periods established by law to comply with regulatory obligations—including tax, commercial, and anti-money laundering regulations—as well as for the duration of the statutory limitation periods.

(g) Disclosure: Your data will not generally be disclosed. However, it may be disclosed to our technology, IT, and/or data hosting service providers essential to fulfilling the purpose for which it was collected, including payment and/or communications service providers; except to authorities where disclosure is required by law or by court order. Your data will not be sold or disclosed to third parties.

(ii) Website Functionality:
(a) Purpose: to enable Users to use and navigate the Web Application.
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(b) Categories of data processed: browsing data, including IP address, browsing habits, usage preferences, language, operating system, approximate location by region and country of access, your device’s operating system, and cookies when necessary to fulfill the purpose (or when consent is obtained from the Data Subject) and anonymized statistical data. 

(c) Categories of Data Subjects: Registered and unregistered Users who use the Web Application.
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(d) Method of collection: through browsing our website.

(e) Legal basis: User consent and our legitimate interest.

(f) Retention period: Personal data will be retained only for as long as necessary to fulfill the purpose for which it was originally collected, up to a maximum of 18 months from that time.

(g) Disclosure: The data collected may be disclosed to our technology, IT, and/or data hosting service providers, which are essential to fulfilling the purpose for which the data was collected. Your data will not be sold or disclosed to third parties.

(iii) Sending Communications to Users: 
(a) Purpose: Sending routine communications or relevant notifications; or commercial communications, offers, promotions, or similar messages regarding the products offered by DOMOBLCOK via postal mail, telephone, email, SMS/MMS, or other equivalent electronic means of communication. If consent is obtained from the Data Subject, personalized commercial communications may be sent to Users in accordance with their interests. ‍

(b) Categories of data processed:
(i) Identifying data (first and last names). 
(ii) Contact information (email address, phone number, mailing address).
(iii) User preferences. 

(c) Categories of data subjects: Registered Users and DOMOBLOCK customers.

(d) Method of collection: directly from the User through the use of the Web Application and the Services. 

(e) Legal basis: DOMOBLOCK’s legitimate interests in contacting Users regarding the Services or in informing Users about its products or relevant information, unless the User withdraws their consent or cancels their account. Withdrawal of consent does not affect the lawfulness of processing prior to such withdrawal.

(f) Retention period: The data will be processed until the User withdraws their consent, and for a maximum of 18 months following such withdrawal. 

(g) Disclosure: Your data will not be disclosed to third-party companies, except to those that provide IT, technological, and/or technical services, and solely for the purpose of ensuring the delivery of SMASH’s commercial communications. Your data will not be sold to third parties.

(iv) Prevention of money laundering and terrorist financing: 
(a) Purpose: verification of the User’s identity, transactions, and financial assessment (KYC/AML) in compliance with obligations related to anti-money laundering and counter-terrorism financing regulations, and other related regulations.
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(b) Categories of data processed:
(i) Identifying data (first and last names, country of origin and residence, and facial photograph).
(ii) Contact information (mailing address, email address, and contact phone number). 
(iii) Image of ID card, passport, or similar document; expiration date; country of residence; place of birth; and facial photograph).
(iv) Financial information.
(v) Professional information and background checks on public figures.

(c) Categories of data subjects: DOMOBLOCK Users. 

(d) Method of collection: directly from the User through the identification and registration process, as well as during the use of the Web Application and/or services.

(e) Legal basis: compliance with a legal obligation imposed on DOMOBLOCK. Refusal to provide such information may result in the inability to use DOMOBLOCK.

(f) Retention period: for the periods legally established by anti-money laundering and counter-terrorism financing regulations, up to a maximum of 10 years. 

(g) Disclosure: Your data will not be disclosed to third-party companies, except to those providing IT, technological, and/or technical services; without prejudice to disclosure to the competent authorities due to a legal obligation or court order. 

(v) Assess whether the user has sufficient authority, capacity, and financial and investment knowledge to invest in the products offered by DOMOBLOCK:
(a) Purpose: to verify the user’s authority, capacity, and financial and investment knowledge to invest in the products offered by DOMOBLOCK. 
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(b) Categories of data processed:
(i) Financial and investment knowledge.
(ii) Professional background. 

(c) Categories of data subjects: DOMOBLOCK users.

(d) Method of collection: directly from the user through the identification and registration process, as well as during the use of the web application and/or services. 

(e) Legal basis: DOMOBLOCK’s legitimate interest in ensuring that the User is qualified to make investments on its platform to prevent legal and/or contractual liability. Refusal to provide such information may result in the inability to use DOMOBLOCK.

(f) Retention period: for the duration of the various statutory limitation periods and, where applicable, for the periods provided for by applicable regulations. 

(g) Disclosure: Your data will not be disclosed to third-party companies, except for those that provide IT, technological, and/or technical services; without prejudice to disclosure to the competent authorities due to legal obligation or judicial order.


(vi) Resolution of inquiries made by Users:
(a) Purpose: To ensure that Users can communicate with DOMOBLOCK regarding customer service inquiries, filing complaints, or other similar matters through any of DOMOBLOCK’s contact points, including the forms made available to the user on the Web Application.

(b) Categories of data processed:
(i) identifying data (first and last names);
(ii) contact information (email address and/or phone number). 

(c) Categories of Data Subjects: Users who use the Web Application and submit an inquiry. 
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(d) Method of collection: directly from Users, when they fill out the contact form or contact DOMOBLOCK directly.

(e) Legal basis: consent from Users or legitimate interest in responding to their request. 

(f) Retention Period: Once the purpose for which the data was collected has been fulfilled, the data will be retained for a maximum period of 18 months, except in the case of claims or situations where, for reasons of legitimate interest, retention for a longer period is required, including statutory limitation periods. 

(g) Disclosure: Your data may be disclosed to our technology, IT, and/or data hosting service providers, which are essential to ensuring the purpose for which the data was collected. Your data will not be sold or disclosed to third parties.
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‍5.- Special Categories of Personal Data ‍In
accordance with Articles 9 and 10 of Regulation (EU) No. 2016/679, “special categories of personal data” will not be processed, defined as data revealing “ethnic or racial origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data intended to uniquely identify a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation,” in accordance with Articles 9 and 10 of Regulation (EU) No. 2016/679. However, should the user decide to share such information, such processing will be carried out with the user’s consent and/or on the basis of reasons of substantial public interest, in compliance in all cases with the provisions of applicable regulations.


‍6.- Method of Processing
The processing of the data provided is based on the principles of lawfulness, transparency, purpose and retention limitation, data minimization, accuracy, integrity, and confidentiality, and will be carried out, in all cases, subject to the relevant provisions of EU Regulation 2016/679 and Organic Law 3/2018 of December 5 on the Protection of Personal Data and the Guarantee of Digital Rights.


‍7.- Retention
In accordance with Article 5.1(e) of EU Regulation No. 679/2016, the data provided will be retained, in accordance with the principles of proportionality and necessity, for a period not exceeding the time strictly necessary to achieve the purposes for which it was collected, until the User revokes their consent or requests the deletion of their account or the erasure of certain personal data from the Web Application.Subsequently, if necessary, DOMOBLOCK will keep the information blocked for the periods established by law or, where applicable, for the statutory limitation periods.


‍8.- Data Security and Confidentiality
Protecting Users’ privacy and personal data is very important to DOMOBLOCK. Therefore, DOMOBLOCK makes every effort to prevent User data from being used inappropriately. Only authorized personnel have access to User data.

DOMOBLOCK is committed to complying with its obligation of secrecy and confidentiality regarding personal data in accordance with applicable law.

DOMOBLOCK maintains adequate security measures to protect personal data in accordance with applicable law and has implemented all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of the data provided by the User through the Web Application, without prejudice to informing the User that security measures on the Internet are not impregnable.


‍9.- Accuracy of Data Provided by Users ‍The
User guarantees the accuracy of the personal data provided and agrees to notify DOMOBLOCK of any changes thereto. The User shall, in any case, be responsible for the accuracy of the data provided, and DOMOBLOCK reserves the right to exclude from its services any User who has provided false information, without prejudice to any other actions that may be available under the law.

Users are advised to protect their data with the utmost care using appropriate security tools. DOMOBLOCK shall not be liable for any theft, unauthorized alteration, or loss of data.

Any modification or update to the data must be communicated to DOMOBLOCK through the means of communication provided for in this Privacy Policy.


‍10.- Disclosure of Personal Data: ‍As
a general rule, DOMOBLOCK will not disclose your personal data to third parties, except when the provision of a service requires a contractual relationship with a data processor and such disclosure is strictly necessary for the management and maintenance of the relationship between the user and DOMOBLOCK, and always subject to the user’s prior express authorization and for the time necessary to fulfill the purposes, and under the same or similar conditions, commitments, and responsibilities regarding privacy and data protection to which DOMOBLOCK is subject. Upon termination of the transfer, such data processors will return the personal data to DOMOBLOCK and delete any copies in their possession.

In this regard, and strictly for the purpose of fulfilling the purposes described in this Policy, DOMOBLOCK may disclose your personal data to the following categories of recipients: 
- Essential service providers, including IT and technology services, such as payment gateway services, cloud storage, and communication delivery services, among others.
- Public authorities, upon judicial order or as required by law.
- Companies and/or consultants who assist us in managing our services and fulfilling our purposes.

The complete and up-to-date list of parties to whom Personal Data may be disclosed or who may become aware of such data in their capacity as Data Processors or Authorized Persons may be requested from the Data Controller through any of the contact points indicated in this Policy. 

In any case, the Personal Data provided will not be disclosed or sold and, therefore, will not be communicated to unspecified parties in any way.
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‍11.- Transfers and/or Disclosures to Third Parties ‍As
a general rule, no transfers of Personal Data are made to third countries or international organizations (“TTI,” hereinafter). However, in order to fulfill the purposes of processing, TTI may be made to our technology, IT, and/or data hosting service providers, which are essential to ensuring the purpose for which the data was collected, provided that the Data Subject has been informed and has given their consent, and always subject to the application of certain safeguards provided for in Articles 44 of the GDPR and following to ensure an adequate level of security in the processing of personal data, including the adequacy decision (list of countries based on an adequacy decision) or through the European Commission’s Standard Contractual Clauses (“SCCs,” hereinafter). 

User data may only be used by DOMOBLOCK for any purpose that serves to properly fulfill the purposes of personal data processing set forth in this Privacy Policy.


‍12.- Automated
Decision-Making There is no automated decision-making process, not even for the purpose of profiling, in accordance with Article 13(2)(f) of EU Regulation No. 679/2016.


‍13.- User
Rights At any time, the User may exercise the following rights in accordance with Articles 15 through 22 of EU Regulation No. 2016/679:

(i) Access their personal data;
(ii) Request the rectification of any inaccurate data;
(iii) Request the erasure of their data;
(iv) Request that the processing of their data be restricted;
(v) Object to the processing of their data;
(vi) Request the portability of their data.
(vii) Furthermore, Users have the right not to be subject to decisions based solely on automated data processing.

‍Users may exercise all these rights by sending an email to the following address: info@domoblock.io, stating the reason for their request and attaching a copy of their national ID card

. Users may also send their request by regular mail to the following address: Calle Presen Sáez de Descatllar 2, 3rd Floor, Door 12, 46018 – Valencia.

Any communication addressed to DOMOBLOCK must contain the following information:
● The User’s first and last names; a photocopy of their national ID card, passport, or other valid identification document.
● A detailed description of the request.

Without prejudice to any other administrative remedy or legal action, the User has the right to file a complaint with the Spanish Data Protection Agency (AEPD) if they have questions or are dissatisfied with the exercise of their rights or our processing of their data. The AEPD’s contact information is as follows:

Spanish Data Protection Agency (AEPD), Spain.
Receiving Office: Calle Jorge Juan, 6 // ZIP Code: 28004 - Madrid
Phone: +34 901 100 099 // +34 91 266 35 17https://www.aepd.es/ ‍14


.- Modifications
DOMOBLOCK reserves the right to modify or simply update the content, in whole or in part, of this privacy policy, including as a result of changes in applicable legislation; we will inform the data subject in a timely manner.


15.- Questions
If you have any questions about our Privacy Policy, please contact us by sending an email to info@domoblock.io.

‍Likewise, if you believe that your rights are not being properly safeguarded, you have the right to file a complaint with the Spanish Data Protection Agency.


16.- Acceptance and Consent
By accepting this Privacy Policy, the User declares that they have been informed of the terms and conditions regarding the protection of personal data and hereby accepts and consents to the processing of such data by DOMOBLOCK in the manner and for the purposes set forth in this Privacy Policy.