1. IDENTIFICATION OF THE DATA CONTROLLER

This Privacy Policy governs the processing of personal data carried out within the context of the Estulin.Media platform and its associated services.

The processing of personal data may be carried out by different entities linked to the Estulin.Media operational ecosystem depending on:

• the contract date;
• the subscription type;
• the associated payment provider;
• or the operational infrastructure used for service provision.

Currently, services may be managed by:

and/or

Both entities may act as data controllers or related processors within the Estulin.Media operational infrastructure when necessary for the provision of services, continuity of active subscriptions, technical support, billing, or compliance with legal obligations.

For any questions related to privacy or data protection, the user may contact via:

[email protected]

2. PURPOSES OF PROCESSING

User personal data may be processed for the following purposes:

• managing registration and access to the platform;
• processing subscriptions, payments, and renewals;
• providing the contracted services;
• managing access to content, memberships, and private communities;
• responding to inquiries, incidents, or support requests;
• sending service-related communications;
• sending commercial or promotional communications when consent or sufficient legitimate basis exists;
• improving the platform’s functionality, stability, and user experience;
• preventing fraud, unauthorized access, or abusive uses;
• ensuring the technical security of the services;
• performing aggregated statistical analyses and usage metrics;
• and complying with applicable legal obligations.

Likewise, certain interactions may be used for technical diagnostic purposes, performance improvement, quality control, and optimization of digital functionalities.

3. LEGAL BASIS FOR PROCESSING

The Company will process user personal data based on one of the following legal grounds:

• the execution of a contractual relationship;
• the provision of services requested by the user;
• compliance with legal obligations;
• consent granted by the user;
• the Company’s legitimate interest in ensuring the security, stability, and improvement of the platform;
• or any other valid legal basis in accordance with applicable regulations.

The user may withdraw their consent at any time when processing is based on said legal ground, without affecting the lawfulness of processing carried out prior to withdrawal.

4. PERSONAL DATA COLLECTED

The Company may collect and process different categories of personal data, including:

Identification Data

• name;
• surname;
• username;
• email address;
• country of residence.

Economic and Billing Data

• payment information;
• subscription history;
• transactions carried out;
• collection incidents.

Technical and Navigation Data

• IP address;
• device identifiers;
• browser;
• operating system;
• access logs;
• cookies and similar technologies;
• interaction and usage metrics.

Voluntarily Provided Data

• inquiries;
• forms;
• messages;
• responses;
• content submitted by the user;
• interactions within communities or conversational functionalities.

The Company does not deliberately request special categories of personal data or particularly sensitive information. The user undertakes not to introduce this type of information unless strictly necessary and legally authorized to do so.

5. DATA PROCESSING IN ARTIFICIAL INTELLIGENCE-BASED TOOLS (“THE ORACLE”)

Estulin.Media may offer functionalities and services based on generative artificial intelligence technologies, including the system called “The Oracle”.

The use of such functionalities may involve the automated processing of:

• queries made by the user;
• instructions entered into the system;
• conversations held through conversational interfaces;
• content generated during interaction;
• and certain technical metadata associated with the service’s operation.

The user expressly acknowledges and accepts that interactions carried out through artificial intelligence-based tools may be processed using technological infrastructures and specialized external providers linked to the provision of the service.

The Company may process such interactions for the following purposes:

• generating automated responses;
• correctly providing the requested service;
• improving stability and technical performance;
• detecting abusive, fraudulent, or unlawful activities contrary to the Terms and Conditions;
• performing diagnostic, support, and quality control tasks;
• optimizing functionalities;
• and developing operational and technological improvements to the platform.

The Company will not sell conversations or personal data derived from the use of The Oracle to third parties for external advertising purposes.

However, certain interactions may be:

• temporarily stored;
• processed by specialized technological providers;
• anonymized;
• statistically aggregated;
• or used internally for technical, operational, and service improvement purposes.

The user expressly undertakes not to introduce into artificial intelligence-based tools:

• particularly sensitive data;
• trade secrets;
• confidential third-party information;
• access credentials;
• critical financial information;
• health data;
• or any content whose disclosure is not legally or contractually authorized.

The Company does not guarantee the absolute confidentiality of information transmitted via the internet or complex technological systems, without prejudice to the adoption of reasonable security measures in accordance with the state of the art.

6. DATA RETENTION

Personal data will be retained for the time necessary to fulfill the purposes for which they were collected, including:

• the provision of contracted services;
• the management of subscriptions and payments;
• the maintenance of the contractual relationship;
• the handling of incidents or claims;
• compliance with legal obligations;
• fraud prevention;
• and defense against potential legal liabilities.

Once the relationship with the user has ended, data may remain duly blocked for the legally required periods before being permanently deleted.

Certain technical, anonymized, or statistically aggregated information may be retained for security, analysis, operational stability, or technological improvement purposes without direct user identification.

7. RECIPIENTS AND SERVICE PROVIDERS

The Company may share certain personal data with third-party providers when necessary for the proper provision of services offered through Estulin.Media.

Among others, providers related to the following may be involved:

• web hosting and cloud infrastructure;
• payment processing;
• email and communication platforms;
• analytical tools;
• artificial intelligence services;
• operational automation;
• technical support;
• security systems;
• incident management;
• or technological maintenance.

Such providers will act according to the Company’s instructions and under the contractual guarantees and legally required protection measures.

The Company does not commercialize or sell personal data to third parties for external advertising purposes.

Likewise, certain data may be communicated when necessary to:

• comply with legal obligations;
• respond to administrative or judicial requirements;
• protect the Company’s legitimate rights;
• prevent fraud or illicit uses;
• or ensure the security of the platform and its users.

The provision of certain services may involve the use of external communication platforms or private communities, including Telegram or other equivalent tools.

In such cases, certain interactions, public user identifiers, or data associated with the external platform’s profile may be visible to other participants according to the specific operation of the service used.

The user acknowledges and accepts that the data processing carried out directly by such external platforms will be governed by their own policies and privacy conditions.

8. INTERNATIONAL DATA TRANSFERS

Due to the international nature of the technological infrastructure used by Estulin.Media, certain personal data may be processed, stored, or accessed from countries other than the user’s country of residence.

In particular, some technological providers, processing platforms, cloud services, or artificial intelligence tools may be located outside the European Economic Area or the local jurisdiction applicable to the user.

The Company will adopt reasonable measures aimed at ensuring that such international transfers are carried out under appropriate safeguards in accordance with applicable regulations, including:

• standard contractual clauses;
• adequacy decisions;
• supplementary technical measures;
• or equivalent legally recognized mechanisms.

The user expressly acknowledges and accepts that the use of global digital services may involve international transfers of information.

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9. USER RIGHTS

The user may exercise their rights at any time in accordance with applicable personal data protection regulations.

In particular, the user may request:

• access to their personal data;
• rectification of inaccurate or incomplete data;
• erasure of their data when applicable;
• restriction of processing;
• objection to processing;
• data portability;
• and withdrawal of previously granted consent.

The exercise of these rights may be carried out by sending a request to:

[email protected]

The request must contain sufficient information to reasonably verify the applicant’s identity and properly manage the request.

The Company may reject requests that are manifestly unfounded, excessive, or contrary to applicable legal obligations.

Likewise, the user shall have the right to lodge a complaint with the competent data protection authority if they consider that their rights have been violated.

10. COMMERCIAL COMMUNICATIONS

The Company may send the user electronic communications related to:

• the platform’s operation;
• technical incidents;
• renewals;
• service updates;
• contractual changes;
• news;
• content;
• promotions;
• or launches related to Estulin.Media.

When legally required, such commercial communications will only be sent with the user’s prior consent or based on another valid legitimate basis.

The user may request to unsubscribe from promotional communications at any time via:

• the mechanisms enabled in each communication;
• their account settings;
• or by writing to [email protected].

The withdrawal of consent for promotional communications will not affect communications necessary for the provision of the service or compliance with contractual obligations.

11. COOKIES AND SIMILAR TECHNOLOGIES

Estulin.Media may use cookies, pixels, identifiers, activity logs, and similar technologies in order to:

• ensure the proper functioning of the platform;
• remember user preferences;
• analyze navigation metrics;
• improve user experience;
• enhance security;
• personalize content;
• and obtain aggregated statistical information.

The use of certain cookies may require the user’s prior consent in accordance with applicable regulations.

The user may configure, block, or delete cookies via:

• the configuration panel enabled on the platform;
• or their browser options.

For more information, the user may consult the corresponding Cookie Policy.

12. SECURITY MEASURES

The Company adopts reasonable technical, organizational, and security measures aimed at protecting personal data against:

• loss;
• destruction;
• alteration;
• unauthorized access;
• improper disclosure;
• unlawful use;
• or any form of unauthorized processing.

Such measures may include, among others:

• access controls;
• encryption;
• technical monitoring;
• system segmentation;
• authentication;
• and operational security mechanisms in accordance with the state of the art and the nature of the services provided.

However, the user expressly acknowledges that no technological system, internet-connected infrastructure, or electronic transmission can guarantee absolute security.

Consequently, the Company cannot ensure the total invulnerability of its systems or fully guarantee the security of electronically transmitted information.

13. MINORS’ PRIVACY

The services offered through Estulin.Media are not directed at minors.

The Company does not deliberately collect personal data from minors.

In case of reasonably detecting the existence of information corresponding to minors without valid authorization from their legal representatives when required, the Company may proceed to:

• restrict access;
• suspend accounts;
• and delete the corresponding data.

Legal representatives may contact the Company to request the review or deletion of data related to minors.

14. MODIFICATIONS TO THE PRIVACY POLICY

The Company may modify, update, or adapt this Privacy Policy at any time in order to:

• reflect regulatory changes;
• incorporate new functionalities;
• adapt new services;
• implement technological improvements;
• or update internal data processing practices.

Modifications will take effect from the moment of their publication on the platform, unless another date is expressly indicated.

Continued use of the services after the publication of changes will imply acceptance of the updated version of the Privacy Policy.

The user is advised to periodically review this document.

15. CONTACT

For any questions related to privacy, personal data protection, or the exercise of rights, the user may contact via:

[email protected]