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Privacy Policy

Last updated: June 29, 2025

I. Privacy and Data Protection Policy

In compliance with current legislation, OCYBE (hereinafter, also Website) commits to adopting the necessary technical and organizational measures, according to the appropriate security level for the collected data.

Laws incorporated in this privacy policy

This privacy policy is adapted to current Spanish and European regulations on personal data protection on the internet. Specifically, it respects the following standards:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
  • Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
  • Royal Decree 1720/2007, of December 21, approving the Regulation implementing Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the data controller

The controller of the personal data collected in OCYBE is: OCYBE, Inc. (hereinafter, Data Controller). Their contact details are as follows:

Contact email: [email protected]

Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by OCYBE, through the forms on its pages, will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between OCYBE and the User or the maintenance of the relationship established in the forms that the User completes, or to respond to a request or query. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR is applicable, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles contained in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

  • Principle of lawfulness, fairness and transparency: User consent will be required at all times following completely transparent information about the purposes for which personal data is collected.
  • Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
  • Principle of data minimization: the personal data collected will be only what is strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: personal data must be accurate and always up to date.
  • Principle of storage limitation: personal data will only be kept in a way that allows the identification of the User for the time necessary for the purposes of its processing.
  • Principle of integrity and confidentiality: personal data will be processed in a way that ensures its security and confidentiality.
  • Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed in OCYBE are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. OCYBE commits to obtaining the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of processing personal data

Personal data is collected and managed by OCYBE with the purpose of facilitating, expediting and fulfilling the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend to a request or query.

Likewise, the data may be used for commercial purposes of personalization, operational and statistical, and activities proper to the corporate purpose of OCYBE, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation and navigation of the Website.

At the time personal data is obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be given to the information collected.

Personal data retention periods

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the legal period established or until the User requests its deletion.

At the time personal data is obtained, the User will be informed about the period for which the personal data will be kept or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, only those over 14 years of age may grant their consent for the processing of their personal data lawfully by OCYBE. If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

OCYBE commits to adopting the necessary technical and organizational measures, according to the appropriate security level for the risk of the collected data, in such a way that the security of personal data is guaranteed and the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data is avoided.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, because OCYBE cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller commits to informing the User without undue delay when a personal data breach occurs that is likely to pose a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss, alteration of personal data transmitted, stored or otherwise processed, or the unauthorized communication of or access to such data.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights derived from the processing of personal data

The User has over OCYBE and may, therefore, exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights:

  • Right of access: This is the User's right to obtain confirmation of whether OCYBE is processing their personal data or not and, if so, to obtain information about their specific personal data and the processing that OCYBE has carried out or will carry out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned for them.
  • Right to rectification: This is the User's right to have their personal data that proves to be inaccurate or, taking into account the purposes of the processing, incomplete, modified.
  • Right to erasure ("right to be forgotten"): This is the User's right, provided that current legislation does not establish otherwise, to obtain the deletion of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data has been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a minor under 14 years of age.
  • Right to restriction of processing: This is the User's right to limit the processing of their personal data. The User has the right to obtain the restriction of processing when they challenge the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
  • Right to data portability: In the event that the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used and machine-readable format, and to transmit it to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
  • Right to object: This is the User's right not to have their personal data processed or to cease the processing of the same by OCYBE.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, existing unless current legislation establishes otherwise.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference "GDPR-OCYBE", specifying:

  • Name, surname of the User and copy of ID. In cases where representation is allowed, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the ID may be replaced by any other legally valid means that proves identity.
  • Request with the specific reasons for the request or information to which you want to access.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document that proves the request you make.

This request and any other attached document may be sent to the following address and/or email:

Postal address: OCYBE, Inc., 123 Tech Street, San Francisco, CA 94103
Email: [email protected]

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than OCYBE, and which are therefore not operated by OCYBE. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the State where they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. Acceptance and Changes to this Privacy Policy

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

OCYBE reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights.