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ISBAES LLC, henceforth referred to as 4 LABS DETAIL, in accordance with current legislation on Personal Data Protection, informs the users of its online application about the Privacy and Data Protection Policy that will apply in the processing of personal data that the User voluntarily provides when accessing the mobile application.

By providing 4 LABS DETAIL with their personal data through the electronic forms of the application, the User expressly consents to 4 LABS DETAIL processing this data in the terms of this Privacy and Data Protection clause and for the purposes stated herein.

Before registering at 4 LABS DETAIL, users must read this Privacy and Data Protection Policy. By clicking the “register now” button, users affirm that they have read and expressly consent to this Data Privacy Policy.

Upon registration, users must provide certain data to create their account and profile. This includes: first name, last name, email, NIE (Foreigner’s Identification Number), phone number, password, and credit card.

Once registration is complete, every user will be able to access their profile and complete or edit it as deemed appropriate. The information and data provided by the User will always be available in their user account and can be modified by the User.

The User commits to entering real and truthful data. Also, they will be solely responsible for any damages that 4 LABS DETAIL may suffer as a result of the lack of accuracy, validity, currency, and authenticity of the data provided.

The data collected by 4 LABS DETAIL will be used exclusively to achieve the purpose defined in the General Conditions of Use.

• Legislation applicable to Users’ personal data (Personal Data Protection).
• Who is responsible for the Data that you provide us?
• What information does 4 LABS DETAIL collect?
• For what purpose is the data collected?
• Does 4 LABS DETAIL share the information it collects?
• What rights do the Users have?
• How do we protect the Users’ data of 4 LABS DETAIL?
• Notifications and modifications

Legislation applicable to Users’ personal data (Personal Data Protection).

4 LABS DETAIL commits to complying with the data protection regulations in force at any time. Users are informed that the personal data provided will be processed automatically and incorporated into the files owned by 4 LABS DETAIL, with 4 LABS DETAIL being responsible for processing for the purposes of managing registered users in the 4 LABS DETAIL application.

Basic information on Data Protection
Identity	ISBAES LLC, ID: 87-4503910
Purpose	Management and provision of requested vehicle washing services
Legitimization	Fulfillment of the contractual relationship, legitimate interest, and consent of the User
Rights	Access, rectify, and delete the data, as well as other rights, as explained in the additional information.
Additional Information	You can consult the additional and detailed information on Data Protection in the following sections.

In accordance with applicable legislation, below is detailed the Privacy Policy that 4 LABS DETAIL uses in processing the data of Users who register in the application.

Who is responsible for the Data that you provide us?

All personal information that you provide or is collected through the application will be processed by 4 LABS DETAIL as the data controller, shown below are their contact details.

Responsible for processing your data
Identity	ISBAES LLC, ID: 87-4503910
Postal Address	1549 NE 123TH STREET NORTH, MIAMI US FL 33161, United States
Customer service phone 4 Labs	‪+34 690 80 16 38‬

What information does 4 LABS DETAIL collect?

The 4 LABS DETAIL application is used by Users. The information we receive from the Users is collected as we outline below.

4 LABS DETAIL collects information from the User that they provide directly and other that is provided indirectly through the use of the 4 LABS DETAIL application

1. a) Information Users provide us directly:

•   Registration Data: the information that the User provides when creating an account on the 4 LABS DETAIL application: First name, last name, email, NIE, phone number, and password.
•   User Profile Information: the information that the User adds to the application to use the 4 LABS DETAIL service, this includes information on their vehicle or vehicles, addresses where the washing service will be performed (work, home, etc). The User can view and edit their personal profile data whenever deemed appropriate. 4 LABS DETAIL does not store the User’s credit card data, but these are provided to licensed electronic payment service providers, who will receive the included data directly and store them to facilitate the payment process to the User and manage it on behalf of 4 LABS DETAIL. Under no circumstances are these data stored on the servers of 4 LABS DETAIL. The User may, at any time, delete the data of their cards linked to their account. With that action, the service provider will proceed to delete the data, and it will be necessary to re-enter or select them to place new orders through the application. At any time the User may request the privacy policies of these providers.
•  Additional information the User wants to share: the information that could be provided by the User to 4 LABS DETAIL for other purposes. For example, additional information that facilitates the service such as the parking space number, where the user will leave the keys for the Cleaner to pick up, etc.
•    Information about communications made with 4 LABS DETAIL: 4 LABS DETAIL will have access to information that Users provide for the resolution of questions or complaints about the use of the application, either via the contact mobile or by email.

The processing of this data by 4 LABS DETAIL is necessary in order to fulfill the contractual relationship established. If the User does not provide them, the requested services may not be available, and 4 LABS DETAIL will not be able to provide them.

1. b) Information that Users provide us indirectly:

– Data derived from the Use of the Application: 4 LABS DETAIL may collect data derived from the User’s use of the Application each time they interact with the Application.

– Application and device data: 4 LABS DETAIL stores the data of the device and Application that the User uses to access the services. These are:

• Internet IP address that the User uses to connect to the Internet with their computer or mobile.
• Information about their computer or mobile, such as their Internet connection, browser type, version and operating system, and device type.
•  The full clickstream of Uniform Resource Locators (URL), including the date and time.
•   User account data: information about the orders placed by the User
• The browsing history and preferences of the User.

 

– Data derived from the origin of the User: if the User arrives at the 4 LABS DETAIL Application via an external source (such as a link from another website or from a social network), 4 LABS DETAIL collects data on the source from which the 4 LABS DETAIL User comes.

– Data derived from the management of incidents: if the User directs to the 4 LABS DETAIL Application via email or through the 4 LABS DETAIL phone, 4 LABS DETAIL will collect the messages received in the format used by the User and may use and store them to manage present or future incidents.

– Data derived from external third parties: 4 LABS DETAIL may collect information or personal data from external third parties only if the User authorizes those third parties to share the aforementioned information with 4 LABS DETAIL. For example, if the User creates an account through their Facebook, Facebook could provide us with personal data of said User in case they had it in their Facebook profile (name, gender, age…).

Similarly, if the user accesses 4 LABS DETAIL through the products and services offered by Google, Google may send the User’s browsing data to 4 LABS DETAIL, with access to the Application through the links created by Google.

The information provided by the external third party may be controlled by the User according to the third party’s own privacy policy.

– Data on Geolocation: as long as Users authorize it, 4 LABS DETAIL will collect data related to their location, including the real-time geographical location of the User’s computer or mobile device.

For what purpose is the data collected?

1.- Use the 4 LABS DETAIL Application

1.1.-4 LABS DETAIL uses the data it collects from Users so that they can access and communicate with the 4 LABS DETAIL application and to provide the vehicle washing services they request through their account in the 4 LABS DETAIL Application, as described in the “Terms and Conditions”. During the execution of a service the data may be used:

By the Cleaner who performs the vehicle washing service.

By Customer Services hired by 4 LABS DETAIL for the purpose of notifying the User about possible incidents or asking them why they gave a negative rating to the service. 4 LABS DETAIL may use the data provided for the purpose of managing incidents that may occur in the provision of services.

By the Payment Application so that they can charge the amount to their account.

1.2- 4 LABS DETAIL may use the personal data that the User provides to make communications via email and/or send SMS to the User about the operation of the service. 4 LABS DETAIL will send messages to the User’s mobile with information related to the status of the requested order, and once it has been completed, 4 LABS DETAIL will send a summary/receipt of the service and its price to the User’s email. By registering in the Application it will be understood that the User accepts this Privacy Policy and therefore authorizes 4 LABS DETAIL to make both communications.

1.3.- 4 LABS DETAIL also uses the information to research and analyze how to improve the services it provides to Users, as well as to develop and improve the features of the service it offers. Internally, 4 LABS DETAIL uses the information for statistical purposes to analyze the behavior and trends of Users, to understand how Users use the 4 LABS DETAIL Application, and to manage and improve the services offered, including the possibility of adding new features to the Application.

The aforementioned treatments are necessary for the execution of the contract that the Users have signed with 4 LABS DETAIL through the Terms and Conditions when registering in the 4 LABS DETAIL Application. The execution of said contract is the basis that legitimizes 4 LABS DETAIL to process their data by it or by said third parties for the purpose of providing the services that Users request through the Application.

2. – Ensure security and a suitable environment for the safe provision of services

2.1.- 4 LABS DETAIL may use the data for the purpose of ensuring the proper use of the services requested in its Application.

2.2.- 4 LABS DETAIL may also use User information for the purpose of detecting and investigating fraud, as well as other illegal activities and potential breaches of our “Terms of Use”. For this purpose, 4 LABS DETAIL may share user data with Applications that analyze fraud operations.

4 LABS DETAIL may make use of the information that Users for the treatments described by the legitimate interest consisting of protecting the proper use of the Application, comply with applicable legislation, as well as ensuring the correct and safe provision of services.

3.- Promotion and carrying out of commercial offers (online and offline)

4 LABS DETAIL uses third-party technology integrated into its Application for the purpose of collecting their data and preferences and using them with CRM systems and advanced technology for the benefit of Users. Thus, through the information collected, the following treatments of their data will be carried out:

3.1.- 4 LABS DETAIL may send promotional messages and/or offers related to the service it offers that may interest the User to the Users’ email. 4 LABS DETAIL may measure and personalize such advertising based on the preferences of 4 LABS DETAIL Users. If the 4 LABS DETAIL User wishes not to receive said information and/or commercial communications, they can opt at any time for the option of “Unsubscribe” in the email itself, and consequently, 4 LABS DETAIL will immediately cease sending said information.

3.2.- 4 LABS DETAIL may also send the User messages and/or offers related to said services through “push” notifications consisting of sending said promotional messages and/or offers to their mobile phone. If the 4 LABS DETAIL User wishes not to receive the commercial communications of this point and the previous 3.1., the User can delete them jointly by deactivating their privacy preferences in their profile with a single click.

3.3.- 4 LABS DETAIL and/or third parties associated with 4 LABS DETAIL, may use the service address entered by the User for the purpose of carrying out promotional activities

3.4.- By using the 4 LABS DETAIL Application, Users may also receive commercial communications from third parties associated with the Application such as Facebook and Google, all depending on the privacy preferences that the User has in said Applications.

The aforementioned treatments will be carried out under the legitimate interest of 4 LABS DETAIL to carry out “marketing” activities for the benefit of Users, as described in the following point. It should be mentioned that Users may make use of their privacy management center for the purpose of unsubscribing from online “marketing” services or canceling their account that they did not agree to receive samples along with orders from 4 LABS DETAIL.

4.- Sharing the data of Users with third parties

4.1- As described in the previous point 3.4., if the User connects their 4 LABS DETAIL account to another social network or to the Application of a third party, 4 LABS DETAIL may use the information provided to that social network or third party, provided that such information has been made available to 4 LABS DETAIL in compliance with the privacy policy of said social network or third party Application.

4.2.- If the ownership of 4 LABS DETAIL changes or most of its assets are acquired by a third party, Users are informed that 4 LABS DETAIL will transfer their data to the acquiring entities for the purpose of continuing to provide the services subject to data processing. The new manager will communicate to the Users their identification data. 4 LABS DETAIL states that it will comply with the duty of information to the relevant Control Authority in case the situations mentioned occur, and will communicate to the Users the change of manager at the time it occurs. This treatment will be carried out by virtue of the contract signed with 4 LABS DETAIL.

4.3.- When a User inserts their card number in the 4 LABS DETAIL Application, it is stored directly by our Payment Applications, which will allow the charge to the User’s account. Such treatment will be carried out as long as it is necessary to execute the contract signed between the User and 4 LABS DETAIL under the Terms and Conditions of the Application.

4.4.- With your explicit consent, 4 LABS DETAIL may transfer your personal data to third parties associated with 4 LABS DETAIL as long as the User had explicitly, informedly, and unequivocally accepted such data transfer and knew the purpose and recipient of the same.

Does 4 LABS DETAIL share the information it collects?

As indicated in the previous section, the personal data that 4 LABS DETAIL collects will be used exclusively to achieve the purpose defined in the “Terms and Conditions”.

For the proper development of the contractual relationship and excellence in service provision, as well as by the legitimate interest of 4 LABS DETAIL, it will share certain personal data of the User with:

– Service providers: third-party service providers of 4 LABS DETAIL who perform services, solve incidents with shipments will have access to the personal information of Users necessary to perform their functions, but may not use it for other purposes. They must treat personal information in accordance with this Privacy Policy and the applicable data protection legislation.

– The User may also receive emails from 4 LABS DETAIL to confirm the order, organize a return, request the User’s rating of the service or receive a summary of the order.

–        4 LABS DETAIL guarantees that all commercial, technical, supplier, or independent third partners are bound by contractually binding promises to process information that is shared with them following the instructions that 4 LABS DETAIL gives them, this Privacy Policy, as well as the applicable data protection legislation.

In choosing service providers, 4 LABS DETAIL may transfer user data outside the borders of the European Economic Area. In these cases, and prior to the shipment, 4 LABS DETAIL will ensure that these service providers comply with the minimum security standards established by the European Commission and that they always treat the data according to the instructions provided by 4 LABS DETAIL. 4 LABS DETAIL may have a contractual relationship with them where service providers undertake to comply with the instructions of 4 LABS DETAIL and to incorporate the necessary security measures to protect the data of the Users.

– Security companies and Law Enforcement Agencies: 4 LABS DETAIL may disclose personal information and account data of our customers when it believes that disclosure is necessary to comply with the law, to enforce or apply the “Terms and Conditions” or to protect the rights, property or safety of 4 LABS DETAIL, its users, or third parties. Therefore, this includes exchanging information with other companies and organizations as well as with Law Enforcement Agencies for fraud protection and credit risk reduction.

– Payment gateway: 4 LABS DETAIL does not store the credit card data of Users. However, the identifying data of the credit/debit card (number and expiration date) are stored by the payment service provider chosen by 4 LABS DETAIL, whose security measures are high as it is PC1 Compliant according to the Data Security Standard for the Payment Card Industry or PCI DSS. If the User requests to delete the data corresponding to the means of payment entered in their profile, the third-party payment service provider will delete such data from their servers.

– Upon legal requirement, 4 LABS DETAIL may share information with executive authority bodies and/or third parties regarding requests for information related to criminal investigations and alleged illegal activities.

– Fraud control service providers: 4 LABS DETAIL will share the data of Users with providers offering fraud control services, to study the risk of operations carried out.

– Service providers for the anonymization of some data: to prevent the misuse of Users’ data by third-party service providers. 4 LABS DETAIL may transfer the data of Users so that they can be anonymized and used solely for the provision of the service to Users. For example, 4 LABS DETAIL may transfer the phone number of Users to third parties to anonymize them and provide them in this format to the providers used to fulfill the services contracted by Users.

– The data of 4 LABS DETAIL Users will not be transmitted to any third party except that (i) it is necessary for the requested services, in case 4 LABS DETAIL collaborates with third parties (ii) when 4 LABS DETAIL has explicit and unequivocal authorization from the User, (iii) when requested by a competent authority in the exercise of its functions (to investigate, prevent or take actions regarding illegal actions) or (iv) lastly, if required by law.

– With the consent of the User: apart from what has been established above, the User will be informed in the event that any information about them is made known to the business partners of the Application and/or web for purposes other than those set out in the Terms of Use of 4 LABS DETAIL, so that they have the opportunity to decide not to share their information.

– With the consent of the User also: to third parties who are not business partners, with no link to 4 LABS DETAIL, provided that there is prior and unequivocal authorization from the User.

None of the previous data communications will include selling, renting, sharing, or otherwise disclosing personal customer information for commercial purposes in a way contrary to the commitments made in this Privacy Policy.

What rights do Users have?

– How long will we keep your data?

The personal data provided will be kept as long as its deletion is not requested by the interested party for a period of 24 months from the last interaction.

In case of withdrawing consent or opposing the processing, the data will be blocked and will no longer be processed, and will be kept for a period of 4 years for the purpose of being able to claim or defend ourselves from possible claims.

– Right to withdraw your consent

At any time the User may withdraw their consent for the processing of data by 4 LABS DETAIL.

To withdraw it, it will be enough for the User to send an email to info@4 LABS DETAIL.es or call the mobile phone listed in the application. The withdrawal of consent may be made at any time by the interested party. Users accept and consent that the withdrawal of consent will imply that 4 LABS DETAIL cannot provide the services typical of its Application.

– What information can Users access?

4 LABS DETAIL gives the User access to a large amount of information about their account and their operations in the application so that they can view, and in certain cases, update such information.

Every User will be able to access their profile and complete or edit it as deemed appropriate. As previously stated, the User may access and create an account through their Facebook profile. The information and data provided by the User will always be available in their user account and can be modified by the User through the edit profile option.

– Rights of access, rectification, deletion, limitation of processing, opposition, and the right to data portability

The right of access is conceived as the right of the user to request 4 LABS DETAIL if it processes any of their data, along with the information established in article 15 of the Regulation.

As established in article 16 of the Regulation, the User may request 4 LABS DETAIL to rectify the data present in its database if they were incomplete.

The right to deletion empowers the User to request 4 LABS DETAIL to delete their personal data in the cases provided for in article 17 of the Regulation.

If the User requested it, based on the conditions of article 18 of the Regulation, 4 LABS DETAIL will limit the use of their data as established in that article.

Article 20 of the Regulation regulates the right to portability that Users have, which will allow them to request 4 LABS DETAIL to send all the data it has in a structured and machine-readable format, being able to request that they transmit it to another manager that the same User requests.

The User will also have the right to oppose the processing of personal data that 4 LABS DETAIL has in its possession as established in article 21 of the same Regulation.

The exercise of the same is very personal, so it will be necessary for the affected party to prove their identity. The exercise of these rights must be carried out in writing signed by the data holder, indicating their address, attaching a copy of their National Identity Document or other accrediting document, addressed to 4 LABS DETAIL, through their contact details.

–  What options do Users have?

As previously indicated, if the User wishes to stop receiving emails from 4 LABS DETAIL, they can adjust their subscriptions in the email tray and press the “You can Unsubscribe” button.

Additionally, Users may choose for 4 LABS DETAIL not to know their geolocation. Most mobile devices provide users with the option to disable location services. This possibility is usually found in the device’s settings menu. If you have any doubts about how to disable the location services of your device, 4 LABS DETAIL recommends that Users contact the manufacturer or the service operator of their device.

Apart from the exercise of the rights described above, Users have the right to file a complaint with the supervisory authority for the knowledge of their claim.

How do we protect the Users’ data?

4 LABS DETAIL has adopted the necessary measures recommended by the European Commission and by the competent authority to maintain the required level of security, according to the nature of the personal data processed and the circumstances of the processing, in order to avoid, as far as possible and always according to the state of the art, their alteration, loss, processing, or unauthorized access. As mentioned above, the personal data provided will not be transferred to third parties without prior authorization from the holder of the same.

Notifications and modifications

As previously indicated, all Users have rights to access, update, and cancel their data, as well as to oppose their processing. You can exercise these rights or make any inquiries regarding the Privacy Policy of 4 LABS DETAIL through their contact details.

Due to the continuous evolution of the activities of 4 LABS DETAIL, this Privacy Policy and the Terms and Conditions may also be modified. 4 LABS DETAIL will send the User notifications about changes and substantial modifications of these documents via email, or through another method that ensures their receipt. In any case, 4 LABS DETAIL will not modify policies or practices to make them less effective in protecting the personal data of our clients stored previously.