Terms of Service
Through our app, the user is offered the possibility of contacting doctors and specialists, allowing users and doctors and specialists to exchange text messages, voice messages, images, videos and any other type of file.
The user will be able to save their basic health data within their profile (medical history) which will include a section for their illnesses and medications. These data will be automatically shared with the specialists assigned according to the user's symptoms by the app itself, in order for them to know their health profile, and who, in turn, may modify them in order to correct, complete and update the information of the user.
Several data inputs are used and processed by our machine learning to make a pre-diagnosis based on the information provided by the user. This will not be, in any case and under any circumstances, a medical diagnosis, an offering of medical prescriptions or a medical emergency care service. Therefore, the guidance based on our technology provided by the doctors and specialists may not be adjusted to the real health situation of the user, due to the lack of: information provided by the user, exploration, verification or medical treatment about it, or as a consequence of a misinterpretation of the communications between Sanno and the user.
Sanno does not make exchange of information with professionals or third-party medical centers to expand, complete or corroborate the information provided to its users.
The user is solely responsible for the information provided on the app, which must be truthful and authentic, and for correctly interpreting the information communicated by specialists through the app based on their queries.
Likewise, the user undertakes to respect the applicable laws and the rights of third parties when using the contents and services of the app.
This service is in no way a substitute to professionals or medical centers, so if the user is feeling unwell and under health emergency, they should speak with a doctor or medical center immediately.
Conditions of access and use of the app
In order to use the app, it will be necessary to download and create a user account. The application will process the data only when it is running by user action in the foreground. The user may manage the permissions granted to the application by accessing the configuration menu, granting or revoking such permissions at any time.
User registration and access codes:
In order to use the services, the user must provide, previously and at the time of registration, all the personal data that are necessary to be able to provide the service, which will be those that are requested in the questionnaire that you will find on the app.
The data requested will be strictly necessary to provide the service with greater efficiency and effectiveness. It will be necessary for the data to be entered to be truthful, accurate, correct and updated, the user being solely responsible for not complying with this obligation against possible damages that may be caused to Sanno or a third party.
The user undertakes to ensure the confidentiality of their access codes, Sanno being excluded from any liability that may arise from the incorrect or negligent use of their codes by the user.
Only people with full capacity to be bound and contract the services offered may use the web. Access and use of the services are aimed at people over eighteen (18) years of age.
The user can close the account at any time, through the website or app itself.
Functioning of communication with doctors and specialists:
The user may request advice from any of the doctors or specialists assigned to them according to their symptoms and that are listed as available.
This does not imply, in any case, the existence of an exclusive link with the professionals. It is a service that is provided collectively and not individually, despite the fact that the user has initiated a consultation with a specific doctor or professional.
Sanno reserves the right for any of the doctors or professionals of the service to continue any consultation or follow-up. Queries will always be resolved by a specialist doctor attending to the query but not exclusively by one of our professionals.
Sanno makes available to the user all the relevant and necessary information on the profile of its specialists: Name, specialty and experience.
Through the app, the user, the doctor or specialist may attach documentation, images, videos, audios or any other type of file for a better understanding between both. The user and the doctor or specialist will be solely responsible for the content they incorporate and the statements they make through the app.
Sanno reserves the right to eliminate, withdraw or modify, without prior notice, all content that violates any of the terms of these Conditions.
Nature and Scope of the services:
The service offered by the web is merely informative or indicative, so it will not be, in any case, a substitute or complementary to a medical service carried out by a professional or medical center. It will not be equivalent to medical assistance, a consultation, nor will it imply emergency medical care. The app does not include the prescription service for drugs or treatments, the use of any specific drug is not recommended or validated.
In the event of poor health or a need for a medical emergency, the user must contact or go to the relevant public or private medical professionals or services since the services obtained through the app cannot be considered as one or a substitute for them.
The information provided through the Sanno app should not be used for self-medication by users.
Sanno does not guarantee that the information or content it provides is current or accurate due to the constant evolution of medicine, and, furthermore, as it is a pre-diagnosis service. The diagnosis is eventually made by a qualified gut health expert or doctor with the analysis and data from users through Sanno.The user is totally prohibited from using any content and information accessed or obtained by virtue of the website or app for illegal purposes, or for purposes that harm Sanno, other users or doctors, as well as for purposes expressly prohibited in these Conditions.
Obligation to make correct use of the web and app:
The User agrees to use the website and app in accordance with the Law and this Legal Notice, as well as morality and good faith. Indeed, the User will refrain from using the page for illegal or prohibited purposes, harmful to the rights and interests of third parties, or that in any way may damage, disable, overload, deteriorate or prevent the normal use of computer equipment or documents, files and all kinds of content stored on any computer equipment of the provider.
In particular, and by way of indication but not exhaustive, the User undertakes not to transfer, disseminate or make available to third parties information, data, content, programs, messages, graphics, drawings, sound or image files, photographs, recordings, software and, in general, any kind of material that:
(A) is contrary, disparages or violates fundamental rights and public freedoms recognized constitutionally, in international treaties and other current regulations;
(B) induces, incites or promotes criminal, denigrating, defamatory, violent actions or, in general, contrary to the law, morality and public order;
(C) induces, incites or promotes discriminatory actions, attitudes or thoughts based on sex, race, religion, beliefs, age or condition;
(D) is contrary to the right to honor, personal or family privacy or people's own image;
(E) in any way damages the credibility of the provider or third parties; and
(F) constitutes illegal, misleading or unfair advertising.
Exclusion of guarantees and liability
Sanno reserves the right to edit, update, modify, suspend, eliminate or terminate the services offered by the web, including all or part of its content, without the need for prior notice, as well as to modify the form or type of access to it.
Possible causes of modification may take place for reasons such as their adaptation to possible legislative developments and changes in the website itself, as well as those that may be derived from the existing standard codes on the matter or for strategic or corporate reasons.
Sanno will not be responsible for the use of the website by a minor, the download and use of the website being the sole responsibility of the user.
The website is provided "as is" and without any kind of guarantee. Sanno is not responsible for the final quality of the website, nor that it serves and fulfills all of its objectives. Notwithstanding the foregoing, Sanno undertakes to the best of its ability to contribute to improving the quality of the website, but cannot guarantee the accuracy or timeliness of its content.
Consequently, Sanno will not be responsible for damages of any kind derived from:
- The availability and technical continuity of the operation of the website. However, it will carry out all the necessary actions to re-establish its services in the event of a technical failure.
- Interferences, omissions, interruptions, computer viruses, breakdowns and / or disconnections in the operational functioning of this electronic system or in the devices and computer equipment of the users, caused by causes beyond Sanno's control, that prevent or delay the provision of services or browsing the web.
- Delays or blockages in use caused by deficiencies or overloads of the Internet or other electronic systems, nor of the impossibility of providing the service or allowing access for reasons not attributable to Sanno, due to users, third parties, or cases of force majeure.
- Any responsibility for damages of any kind that may be due to the access and use of the information and content obtained through the application.
- Any error or omission that may be in the content or services.
- Any damage arising from the use of the website from misuse.
- Any action carried out on the basis of the information provided therein.
- Any responsibility for damages of any kind that may be due to the actions of said doctors in the matter of clinical judgment, since the user is not going to the doctor or a medical consultation for an act of a care nature but to a website that offers an orientation service, and, therefore, not a substitute.
- All liability of any kind for damages caused by suppliers, or centers, professionals or specialists hired by Sanno to provide the services that are the object of this contract due to misuse of the website or medical guidance.
In particular and without limitation, the user must not:
- Register or communicate data that is not true, exact, complete and / or updated. Thus, in the event that the data does not conform to the reality of the moment, it must be updated on the app.
- Access the service provided by Sanno using the name, identification data or password of another user or impersonate any person or entity.
- Use Sanno services for uses other than personal and private. The resale or provision of services using the information and services obtained through Sanno is also prohibited. In particular, it will be understood as such to use the service to collect any data from other users.
- Use the service to communicate any information or content that is contrary to the rights of other people, such as those that are defamatory, aggressive, obscene, sexually explicit, offensive, violent or inciting violence, racist or xenophobic, or in general of an illegal nature.
- Violate the intellectual or industrial property rights of Sanno or third parties.
- Infringe the rights related to personal data, privacy or protection of the image of any natural or legal person or the reputation of any third party through the service provided by Sanno.
- Send or disseminate information, codes or content that may reduce, harm, disrupt or prevent the normal use of the service by any other user, or that may damage or harm the equipment or property of Sanno or other users, including, without limitation, malicious applications, viruses, sending of unsolicited messages (spam), etc. Sanno reserves the right to delete messages sent by a user, in order to maintain a good quality of use of its service.
- Send requested or unsolicited commercial communications, or any other type of advertising not authorized by Sanno by any means (including without limitation by email, SMS or any other means of communication), neither to third parties nor to any other user of the service provided by Sanno.
- In any case, the user will be solely responsible for any loss or damage, direct or indirect, that may be caused to another person due to the breach of these Conditions, as well as for damages caused to Sanno due to the incorrect use of its services. and for providing data that are not true, exact, complete and current and of the behaviors that damage, disable, overload, deteriorate or impede the normal functioning of the web.
Among the links provided, there is the possibility of informing or referring to third party products and / or services. Given that from the web we cannot control the content entered by third parties, Sanno does not assume any type of responsibility regarding said content, nor does it guarantee the experience, integrity or quality of its products. In any case, the provider declares that it will proceed to the immediate withdrawal of any content that could contravene national or international legislation, morality or public order, proceeding to the immediate withdrawal of the redirection to these websites, informing the competent authorities the content in question.
From the website, you may be redirected to sponsored content, advertisements and / or affiliate links and / or third-party websites.
Sanno will have these links published until they are eliminated or suspended by the provider or by the advertiser, and will not be responsible even if these ads may be indexed by other search engines outside this website.
The provider is not responsible for the information and content stored, by way of example but not limited to, in forums, chats, blog generators, comments, social networks or any other means that allows third parties to publish content independently on the website of the lender. However, and in compliance with the provisions of art. 11 and 16 of the LSSICE, the provider makes itself available to all users, authorities and security forces, and actively collaborating in the withdrawal or, when necessary, the blocking of all those contents that may affect or contravene the national or international legislation, third party rights or morality and public order. In the event that the user considers that there may be some content that could be susceptible to this classification, please notify the website administrator immediately.
However, Sanno informs you that any contractual or extra-contractual relationship that the user formalizes with these third parties, affiliates or advertisers through the link provided by this website, will be valid solely and exclusively between the user and the advertiser and / or third person and Sanno will not have any type of responsibility for the damages or losses that may be caused by the provision of services and / or contractual or extra-contractual relationships between the user and the advertisers or third parties contacted through this portal since the provider only acts as an intermediary or advertising medium.
Protection of Personal Data
Sanno is deeply committed to complying with the personal data protection regulations and guarantees full compliance with the obligations set forth, as well as the implementation of the security measures provided in the European Data Protection Regulation.
Intellectual and Industrial Property
The website and app, including but not limited to: the programming, editing, compilation and other elements necessary for its operation, the designs, logos, texts, photographs and / or graphics are the property of the provider or, if necessary, has the license or express authorization from the authors. All the contents of the website and app are duly protected by intellectual and industrial property regulations.
Regardless of the purpose for which they were intended, the total or partial reproduction, use, distribution and public communication require prior written authorization from the provider. Any use not previously authorized by the provider will be considered a serious breach of the intellectual or industrial property rights of the author.
The designs, logos, text and / or graphics outside the provider and that may appear on the website and app, belong to their respective owners, being themselves responsible for any possible controversy that may arise with respect to them. In any case, the provider has the express and prior authorization from them.
The provider acknowledges in favor of their owners the corresponding industrial and intellectual property rights, not implying the mention or appearance on the website, of the existence of rights or responsibility of the provider over them, nor endorsement, sponsorship or recommendation by part of the same.
To make any type of observation regarding possible breaches of intellectual or industrial property rights, as well as any of the contents of the website, you can do so through the email mentioned above.
Applicable Law and Jurisdiction
For the resolution of controversies or issues related to this website or the activities carried out in it, UK legislation will apply, to which the parties expressly submit, being competent to resolve all derivative conflicts or UK Courts and Tribunals related to its use.
Your privacy is important to us, so through this document, we explain what data we collect from users, how we use it and for what, among other indications. Those over 18 years of age may register as users without the prior consent of their parents, guardians or legal representatives. In the case of minors under 18 years of age or identified as "legally incapable", we will always need parental consent, or the guardian or legal representative.
For your information, we will never ask for more information than we actually need for the required services. We will never share it with third parties, except by legal obligation or with your prior authorization; and we will never use your data for another purpose not previously indicated.
RESPONSIBLE FOR THE TREATMENT:
Identity: Sanno Ltd (also the provider)
NIF: UK COMPANY NUMBER 12785426
Postal address: 3 The Courtyard, Timothy's Bridge Rd Stratford - Upon - Avon, CV37 9NP United Kingdom
Sanno Ltd, as responsible for the website and app, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (GDPR) with regard to the processing of personal data and the free circulation of these data and other current regulations on the protection of personal data, and by Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSICE), informs you that it has implemented the necessary security measures, of a technical and organizational nature, to guarantee and protect the confidentiality, integrity and availability of the data entered.
DATA OBTAINING METHOD and DATA WE COLLECT: The data we collect and how we obtain it is as follows:
1. Through the registration and contact form: name, email
2. Through the newsletter subscription form: name, email, country
Specially protected categories of data are treated.
PURPOSE OF THE TREATMENT:
Your personal data will only be used for the following purposes, giving your consent for each of the purposes in the corresponding section of the website:
1. Contact form: to respond to inquiries and / or provide information required for the User;
2. Registration form: for the creation of a user account and to be able to access the functionalities of the web and app;
3. Newsletter subscription form: to send commercial advertising communications by email, SMS, social communities or any other electronic or physical means, if the User has expressly consented to it;
4. If you contract the service / purchase the product through our website https://www.sanno.health or app we will ask you to provide us with information about yourself, including your name, contact information and information about a credit card or debit.
The pictures that are posted on the website and app are the property of Sanno Ltd including those of minors, in which, to obtain these, the prior consent of parents, guardians or legal representatives has been obtained by signing the forms made for this purpose by the centers in which the minors are part. However, the parents, guardians or representatives of the minors, as holders of the exercise of their rights, and always after a formal written request, may indicate the refusal to use the image of the minor; in this case, the image will be pixelated
You can revoke your consent at any time by sending a letter with the subject "Unsubscribe" in the email reviewed.
According to the LSSICE, Sanno does not carry out SPAM practices, therefore, it does not send commercial emails that have not been previously requested or authorized by the User. Consequently, in all the communications that the provider will receive, the user has the possibility of canceling their express consent to receive our communications.
We will not process your personal data for any other purpose than those described except by legal obligation or judicial requirement.
It will not be the subject of decisions based on automated treatments that produce effects on your data.
LEGITIMATION OF THE TREATMENT
The legal basis for the treatment of the data is your consent granted at the time of giving your data in the corresponding form to carry out the purposes, at the time of marking the checkbox.
In cases where there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, fiscal, accounting and labor obligations that are necessary under current legislation will be the prior existence of the commercial relationship established between the parties.
The prospective or commercial offer of products and services is based on the consent that is requested, without in any case the withdrawal of this consent conditioning the execution of the subscription contract.
DATA CONSERVATION PERIOD:
Your data will be kept for the duration of the commercial relationship with us or you exercise your right of cancellation or opposition, or limitation of treatment. However, we will keep your data within the legally established deadlines in the applicable provisions.
RECIPIENTS OF ASSIGNMENTS OR TRANSFERS:
Sanno Ltd does not carry out any transfer or communication of data either inside or outside the EU. The provider will only provide information to the security forces and bodies under judicial order or due to the obligation of a legal norm, without prejudice to being able to block or cancel your account if there may be indications of the commission of a crime by the user. The information provided will only be that available to the provider at that time.
The information you provide us both through this website and through the application will be hosted on the servers of Sanno Ltd, contracted to the company that provides the web hosting service. The processing of the entity's data is regulated by means of a contract for the person in charge of the treatment between the provider and this company.
Likewise, the provider uses certain tools to provide services necessary for the development of the activity, being able to store your data. These tools are as follows:
Google Analytics: to perform an analysis and metrics of the use that users make of the web and app through cookies. The information generated and collected by these cookies on the use (including the IP address) will be directly transmitted and filed by Google Inc., located in Delaware, 1600 Amphitheater Parkway, Mount View (California), CA 94043 in the United States ("Google”), on its servers in the United States.
- Right of access: allows the interested party to know and obtain information about their personal data subjected to treatment.
- Right of rectification: allows you to correct errors and modify the data that turn out to be inaccurate or incomplete
- Right of cancellation or deletion: allows data that is inappropriate or excessive to be deleted.
- Right of opposition: right of the interested party not to carry out the processing of their personal data or to stop it.
- Limitation of the treatment: it entails the marking of the personal data kept, in order to limit its future treatment, for the exercise or defense of claims.
- Portability of the data: facilitation of the data object of treatment to the interested party, so that he can transmit it to another person in charge, without impediments.
- Right not to be subject to automated individual decisions (including profiling): right not to be subject to a decision based on automated processing that produces effects or significantly affects
As a user, you have the right to withdraw the consent given at any time. The withdrawal of consent will not affect the legality of the treatment carried out before the withdrawal of consent.
You also have the right to file a claim with the supervisory authority if you consider that your rights may have been violated in relation to the protection of your data.
The data you provide us will be treated confidentially. The provider has adopted all the technical and organizational measures and all the necessary levels of protection to guarantee the security in the treatment of the data and avoid its alteration, loss, theft, treatment or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the treatment and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in current regulations.
The information provided in the different forms, during the interaction with the web and any other data provided during browsing, including the information provided by cookies in relation to browsing habits, implies acceptance of the processing of these data, in order to be segmented or categorized in order to apply them to the activity related to the management of general administration, information, commercialization of advertising spaces, elaborate profiles, analysis of proposals requested by users / clients, statistical study of the services and contents used, tastes and preferences , surveys or forms. The data used in the elaboration of these profiles is not data that allows to identify the users but only shows in a graph the type of public that interacts with the web, age, country, gender, etc.
The user who accesses this website, explicitly consents to the use of this generic information for profiling, segmentation and categorization of data for the purposes described in the previous section.
Changes to this Privacy Pol
Sanno Ltd reserves the right to modify this policy to adapt it to new legislation or jurisprudence.
The consent given, both for the treatment and for the transfer of the data of the interested parties, is revocable at any time by communicating it to Sanno Ltd in the terms established in this Policy for the exercise of rights. This revocation will in no case be retroactive.
In general, the relations between Sanno Ltd and the Users of its telematic services, present on this website, are subject to the legislation and jurisdiction of the UK to which the parties expressly submit, being competent for the resolution of all derivative conflicts or related to its use by the Courts and Tribunals of the UK.
WHAT ARE COOKIES?
A cookie is a file that is downloaded to your computer when you access certain web pages. Cookies allow a web page, among other things, to store and retrieve information about the browsing habits of a user or their equipment and, depending on the information they contain and the way they use their equipment, they can be used to recognize the user. Cookies are only associated with an anonymous user and their computer or device and do not provide references that allow their personal data to be known.
COOKIES AFFECTED BY THE REGULATIONS AND EXEMPT COOKIES
According to the EU directive, the cookies that require the informed consent of the user are analytical cookies and those for advertising and affiliation, excepting those of a technical nature and those necessary for the operation of the website or the provision of services. expressly demanded by the user.
TYPE OF COOKIES
a) Depending on the entity that manages them, there are own Cookies (those that are sent to the user's terminal equipment from a computer or domain managed by the editor itself and from which the service tendered by the user is provided) and third parties (those that are sent to the user's terminal equipment from a computer or domain that is not managed by the publisher, but by another entity that processes the data obtained through cookies).
b) Depending on the time they remain active, there are the session ones (designed to request and store data while the user accesses a web page) and the persistent ones (in which the data is stored in the terminal and can be accessed and processed during a period defined by the person responsible for the cookie - it can range from a few minutes to several years).
c) Depending on the purpose for which they treat the information they collect, they may be:
- Technical cookies (necessary for the use of the website and the provision of the contracted service),
- Personalization cookies (which allow the user to access the service with predefined characteristics, such as language, browser type, regional configuration, etc.)
- Analysis cookies (they collect information on the use made of the web),
- Advertising cookies (they collect information about the preferences and personal choices of users),
- Affiliate cookies (they allow you to track visits from other websites, with which the website establishes an affiliation contract).
While browsing our website, cookies from our social networks may be stored in your browser. Below, we indicate the links on the cookies of the social networks that we use on this website:
- Pinterest cookies, see more information in their cookies policy
You can access your browser settings at any time by accepting or rejecting all cookies, or by selecting those that the installation supports and those that do not, by following one of the following procedures, which depends on the browser you use:
Google Chrome (in the Tools Menu):
Settings> Show advanced options> Privacy (Content settings)> Cookies:
Microsoft Internet Explorer (in the Tools Menu):
Internet Options> Privacy> Advanced:
Options> Privacy> Cookies:
Safari, iPad and iPhone:
Settings> Options> Advanced> Cookies
You can access your browser settings at any time by accepting or rejecting all cookies, or by selecting those that the installation supports and those that do not, by following one of the following procedures, which depends on the browser you use:
These browsers are subject to changes or modifications, so we cannot guarantee that they fully conform to the version of your browser. It may also be that you use another browser not covered by these links such as Konqueror, Arora, Flock, etc. To avoid these mismatches, you can access it directly from your browser options, generally in the "Options" menu in the "Privacy" section. (Please consult your browser's help for more information).
DEACTIVATION / ACTIVATION AND ELIMINATION OF COOKIES
To restrict or block cookies, it is done through the browser settings.
If you do not want websites to place any cookies on your computer, you can adapt your browser settings so that you are notified before any cookies are placed. In the same way, you can adapt the settings so that the browser rejects all cookies, or only third-party cookies. You can also delete any of the cookies that are already on your computer. Remember that the configuration of each browser and equipment you use must be adapted separately.
Remember that if you do not want to receive cookies, we can no longer guarantee that our website works as intended. Some site features may be lost and you may no longer be able to view certain websites. Also, declining cookies does not mean that you will no longer see advertisements. The ads simply will not be tailored to your interests and will be repeated more frequently.
Each browser has a different method to adapt the settings. If necessary, refer to the help function of the browser to configure the correct settings.
To disable cookies on your mobile phone, see the device manual for more information.
You can obtain more information about cookies on the Internet, http://www.aboutcookies.org/.
Taking into account the way the Internet and websites work, we do not always have information about the cookies placed by third parties through our website. This applies especially to cases where the website contains what are called embedded elements: texts, documents, images or short movies that are stored elsewhere, but are displayed on or through our website.
Therefore, in case you come across these types of cookies on this website and they are not listed in the previous list, please let us know. Alternatively, contact the third party directly to request information about the cookies it places, the purpose and duration of the cookie, and how it has guaranteed your privacy.
INFORMATION RELATED TO THE PROCESSING OF PERSONAL DATA (ART. 13 RGPD)
Who is responsible for the processing of your personal data?
Sanno Ltd is responsible for the treatment of the personal data that you provide us, located at 3 The Courtyard, Timothy's Bridge Rd Stratford - Upon - Avon, CV37 9NP United Kingdom and with Telephone +447951383513 and contact email email@example.com.
What do we use your personal data for?
The information collected through own cookies (session cookies and user input cookies) are often used to track user actions when filling in online forms on various pages, or as a shopping cart to keep track of the items that the user has selected by pressing a button, or to customize the user interface when visiting the web page.
The information collected through third-party cookies is as follows:
- Through analytical cookies, your browsing habits are analyzed to improve the services provided;
- Through behavioral cookies, information about user preferences is collected to manage advertising spaces in the most efficient way possible; and
- Through advertising cookies, the performance of the advertisements is measured and recommendations regarding products are provided based on statistical data.
What is the legal basis for the processing of your personal data?
The legitimacy for the processing of your personal data is given by your consent, granted at the time of contacting us, for the use of analytical, behavioral and advertising cookies; For session or personalization cookies, the legitimacy for the treatment is given by the legitimate interest of the provider (responsible for the treatment).
Who do we communicate your data to?
What is the term of conservation of your data?
What are your rights?
The rights that protect the user are those of access, rectification, deletion, portability of the same, withdrawal of consent (without affecting the legality of the treatment granted prior to its withdrawal), opposition to treatment, limitation (in certain circumstances) and to file a claim with the control authority (the Spanish Data Protection Agency, www.aepd.es equivalent to UK).