1. IDENTIFICATION

1.1. Hereto the user may find the data regarding the data controller:

• Controller: RP Group AB

• VAT/TAX No: W0304090D

1.2. We consider as users to any natural person that access the website, without regarding if they are registered or not.

2. INFORMATION AND CONSENT

2.1. We inform that regarding what is set forth in the General Data Protection Regulation and the Organic Law on Personal Data Protection and Guaranty of the Digital Rights, as well as other applicable rules, accepting the herein privacy policy implies that the consent is provided for each and all of the purposes hereto.

2.2. Likewise, if at any time should the users require us to stop processing their personal data, they will be able to contact us in order to exercise their rights as data subjects or to arise any question concerning the processing of the data.

2.3. In RP Group we comply with all the principles relating to processing of personal data such as, including but not limited to, lawful, fair and transparent process, collection of the data for specified, explicit and legitimate purposes and not further processing in manners incompatible with these purposes; adequacy, relevance and limitation of the processing to what is necessary in relation to the purposes; accuracy and update of the data processed; limitation and restriction of the storage of data; and lastly integrity and confidentiality of the data processed.

2.4. All data requested is necessary for the purposes herein described, such as the advertising and contact activities carried out here. Inasmuch as afore mentioned the user shall assure that the provided data are all adequate, relevant, trustworthy, and accurate, moreover users shall not provide false information. Likewise, users must assure to had had requested enough consent from the data subject being the case in which they do not have provided their true information, since it is their sole responsibility to be liable for any prejudice or harm caused either direct or indirectly.

3. DATA CATEGORIES

3.1. These are the categories of personal data that RP Group process regarding the current website and e-commerce.

3.1.1. Identification data (name, surname, ID, address, email, date of birth, etc.)

3.1.2. Metadata, collected by the means of the installed cookies.

3.1.3. Contact details (postal address, email)

3.1.4. Any relevant details or features the users would like to provide (height, weight, nationality, complexity, etc.)

4. PROCESSING PURPOSES

4.1. RP Group informs that in addition so as to manage the website we do process users’ data with the following purposes:

4.1.1. Control of the relationship between RP Group and the users.

4.1.2. Answer and respond to inquiries and requests.

4.1.3. Process users’ log ups.

4.1.4. Publishing and communication at masajecontactos.com of the personal data and main features provided by the users in relation to their services.

4.1.5. Control, intermediation and management of the offers and published ads.

4.1.6. Transfer of the ad to other linked and related websites.

4.1.7. Commercial communications, new offers and services information.

4.1.8. Evaluation and statistical examination of the clients and escorts.

4.1.9. Commercial communications delivery, newsletters, news, periodical information through any mean, included but not limited to electronic means.

4.1.10. Incidents and risks management.

5. LAWFULNESS OF PROCESSING

5.1. At all times the foundation for the processing is the user consent for all processing and purpose herein described. Consent shall be provided by the means offered such as checkbox, questions or any other mean that would appear at the log up, log in or the cookies acceptance.

6. DATA RETENTION

6.1. Data shall not be kept for no longer than is necessary for the purposes for which the data are processed.

6.2. Being the consent the foundation by which we are legitimated to collect and process data, these shall be blocked and when applicable erased by the time the user withdraws its consent or when data became unnecessary for the purposes described. Users may withdraw their consent by the means herein provided. However, data may be stored for longer than necessary, appropriately blocked or pseudonymised, until the event of prescription of certain obligations and legal responsibilities which are hereinafter described:

6.2.1. Conservation of invoices and tax related documents: 4 years.

6.2.2. Conservation of AML&FT related documents: 10 years.

6.2.3. Metadata associated to the visits and mails: 1 year.

6.2.4. Contractual and extra contractual obligations related documents: 5 years.

6.3. Conservation performed by RP Group shall imply the pseudonymisation or blocking of the data so as to ensure its integrity and confidentiality.

7. TRANSFER OF DATA

7.1. Here at RP Group we neither sell nor rent our databases to third parties.

7.2. At RP Group there is no possibility that we transfer data for further purposes apart form the described, inasmuch as we are the data controllers and therefore responsible for them, that is to say that we are the only ones to send commercial communications and that we do not rely on third parties to execute the daily tasks.

7.3. We inform that the processed data will not be object of international transfers to third parties outside the European Union over which the Commission has decided that the referred third country, a territory or one or more specified sectors within that third country, or the international organisation in question ensures an adequate level of protection. Hence, data shall not be transferred unless a legal binding obligation is applicable.

8. DATA SECURITY AND INTEGRITY

8.1. The security and integrity of users’ data is vital at RP Group so we process data under maximum applicable security measures, both legal and technical, given the risk level we detect.

8.2. We consider reasonable proceedings for avoiding unlawful access and improper usage of the personal data.

8.3. We do use commercial and appropriate proceedings to protect persona data provided by the users. We also use security, both physical and technical measures and restrictions in order to access and use of the personal data hosted at our servers. Only the authorised personnel shall have access to the personal information.

9. MINORS’ PERSONAL DATA

9.1. The services offered at RP Group are not for minors.

9.2. Users shall reveal at all times their real age, where the user falsify its data it may be liable for any harm or prejudice caused to us, either direct or indirect, that would be caused as consequence of providing an unreal age.

9.3. Should be the case in which RP Group acknowledge by any mean that is processing minors’ personal data we reserve the right to erase all data, either collected or processed, relevant to the minor.

10. DATA SUBJECT RIGHTS

10.1. At RP Group we are profoundly committed to the users’ data protection rights so we ease that the users control their data. But how?

10.1.1. Any of the following rights may be freely exercised with no limit but the legal established meeting the following instructions and by the means that allows to certify its sending and delivery:

(a) Right to receive transparent information, communication and modalities for the exercise of the rights of the data subject;

(b) Right of access (users shall have the right to obtain from RP Group confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to the personal data and information about the processing);

(c) Right to rectification (to obtain from the controller without undue delay the rectification of inaccurate personal data ) and right to erasure (‘right to be forgotten’) (to obtain from the controller the erasure of personal data)

(d) Right to restriction of processing (to obtain from the controller restriction of processing).

(e) Right to object (right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point [e] or [f] of Article 6(1), including profiling).

(f) Automated individual decision-making, including profiling (right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her ).

(g) Right to data portability (to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller).

10.2. Likewise, users shall have the right to file a claim against us concerning its exercise of their personal data rights before the supervisory authority (AEPD)

10.3. In order to exercise the users’ personal data rights appropriately, users shall take into account the following steps:

10.3.1. Please, use properly the application form you may find at the following website.

10.3.2. Fill a request per right to be exercised.

10.3.3. Attach to the request a proper ID document such as ID. Card or Passport.

10.3.4. Duly incorporate any relevant information regarding your address and mean of contact.

10.3.5. Send the application and attached document through a sending mean that permits verification of sending and delivering.

10.4. Herein you may find the contact details to which the request shall be sent:

Text Box 7

11. REVISION

11.1. We reserve the right to change or amend at any time, either fully or partially, the website or the terms and conditions applicable to the use of the latter. Any change to the privacy policy would be duly notified to all registered user with no delay. However, given that we may not be able to reach to all users, please consider to read from time to time the herein terms and conditions applicable to the data processing.

[2023-04-01]