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UNION AVATARS PRIVACY POLICY (Full text / second layer)

  1. Introduction

    In compliance with the provisions set forth in (i) the European General Data Protection Regulation (EU) 2016/679 ("GDPR"); and (ii) the Spanish Act 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights ("LOPDGDD"), LINKING REALITIES, S.L. (“UNION AVATARS”, “we”, “us” or “our”) has drafted this privacy policy (the “Privacy Policy”) with important information about us, how and why we collect, store, use and share your personal data, what are your personal data protection rights and how you can exercise them before the competent authorities, so we ask you to read this document carefully.
    This Privacy Policy applies to your use of the website (the “Website”); (ii) any subdomain of the Website; (iii) any services and/or products accessible through the Website or any of its subdomains, and/or derivatives works generated through the access to our Website and (iv) to the management of the commercial service relationship between UNION AVATARS and you (the “User”, “you” or “your”).
    For the purposes of this Privacy Policy, hereinafter, the Website, the Web App and the Photobooth and any subdomain of the Website shall be jointly referred to as the “Websites”.

  2. Data Controller

    a Spanish limited liability company with address at
    Carrer de la Llacuna, 162, 08018-Barcelona (Spain) and ID Tax number B-02658839,
    will process your personal data as the data Controller.

  3. Contact information

    For any question, request, doubt or suggestion related to this Privacy Policy or to the data processing carried out by UNION AVATARS, you can contact us by sending an e-mail to

  4. What kind of personal data do we collect?

    1. Identity and biometric data:

      these data include your first name, surname, last name, username and password of your user account, your social networks’ username (where applicable) as well as the images of your face which will also include color and depth perception markers in order to allow us to create your Avatar in a 3D format.

    2. Contact data:

      these data include your address, billing address, telephone numbers and e-mail address.

    3. Technical and navigation data:

      hese data include your IP (internet protocol) address, login data, browser information, time zone setting and location, operating system and platform, and other technology on the devices you use to visit our websites and access to our services.

    4. Communications Data:

      these data include your communication preferences with us, like phone calls, e-mails or any other means of communication made available to you at any time, and your preferences in receiving commercial communications, as well as data you provide us through satisfaction customer surveys. If applicable, it shall also include any personal data contained in the communications or requests that you might make.

  5. How do we obtain your personal data?

    1. From you:

      We collect your personal data directly from you when you access our Websites, register with us, contact us, send us any feedback, use our services or subscribe to services via any of our websites and/or when you complete our customer satisfaction surveys. We also obtain your personal data indirectly when, for example, you are an authorized user of one of our customers.

    2. From the cookies:

      Please note that our Websites use own and third party cookies. If you browse or visit our Websites, some information may be stored in the form of a cookie on your local device. Cookies are small text files that are downloaded to your electronic device when you access our Websites. Among other things, cookies are used not only to enable and ease your navigation through our Websites but also to allow us to understand how users browse our Websites to be compared and understood, which then helps to improve everyone’s browsing experience and to detect website malfunctions.
      We collect your personal data automatically via cookies which help us to improve the use of our Websites as smooth as possible for you and help us to recognize the users device and store some information needed to understand the preferences and needs of our users. For further information about the cookies we use, please read our Cookie Policy.

  6. What are the purposes and legal basis for the processing of your personal data?

    We need to process your personal data in order to be able to fulfill, firstly, your request for the creation and management of your user account with us. In line with the foregoing, after having become a user we will use your personal data for the creation of your personalized 3D digital representation (the “Avatar”), which shall be the subject of the agreement reached between You and UNION AVATARS for the provision of the referred service by our side. The processing of your personal data for the above-mentioned purposes is based on the execution of such agreement. However, we need your prior consent, also as a legal basis, in order to process the images obtained for the designing of your personalized Avatar.
    Another reason for the processing of your personal data is the improvement of our services, technology, user experience, platforms quality, as well as to carry out scientific research with the purpose of improving and developing our technology, including to carry out machine learning, AI and algorithm development, being the legal basis of such processing our legitimate interest of running our business, provision of and development to our services and to ensure network security.
    In addition, we process your personal data with the purpose of promoting our services that may be of your interest, considering, if applicable, those you have already hired in the past and also to promote services or commercial campaigns of our partners related to our business activities. Commercial actions may be carried out by any kind of communication media, including telematic media (e.i. email, SMS, social networks, mobile applications, opinion and satisfaction surveys regarding the services hired by you). In this case, the legal basis is, as applicable, the Spanish Law 34/2002, of July 11, 2002, on information society services and electronic commerce and our legitimate interest to keep our users duly informed and updated about our services improvements, promotions, partnerships, contests or news.
    Users can, at any time, unsubscribe from such commercial communications by clicking on a link which is contained in our commercial communications or by sending an e-mail to "Ref: Data Protection".
    Furthermore, we need to process your personal data in order to comply with applicable legal and tax obligations to which we are subject to. Compliance with such legal obligations is therefore the legal basis of such personal data processing.
    Also, we process your personal data for enforcing and defending our legal rights under legitimate interest pursued by us.
    Finally, we process your personal data in order to enable your navigation through our Websites, in accordance with the provisions of our Cookie Policy.

  7. Below you can find a list with your personal data protection rights according with the GDPR:

    1. the right to request access to your personal data;
    2. the right to request the rectification of your personal data if such data provided by you are inaccurate or incomplete;
    3. the right to request the erasure of your personal data if the legal basis of its processing is finished or if any of the applicable scenarios under which the right to erasure your personal data can be exercised applies;
    4. the right to request the restriction of processing of your personal data;
    5. the right to object to the processing of your personal data;
    6. the right to request the portability of your personal data;
    7. the right that decisions shall not being taken concerning you if such decisions are based on automated decision-making; and
    8. the right to withdraw a consent at any time;

    You may exercise these rights by sending an express request to You can also file a complaint before the Spanish Data Protection Agency if you disagree with the response you have received. The necessary information is available on its website

  8. Minors policy

    According with the applicable law, you must be at least 16 years old to visit our Websites and use our services.

    According with the above, you hereby expressly declare and acknowledge that, in case of provide us with personal data of any children under 16 years, you have obtained the express consent of the parent or guardian of such children prior to providing us with such personal data.

    Please contact us if you suspect or become aware of any unauthorized use of personal data of children under 16 years in our Websites.

  9. How do we obtain your data?

    We will store your personal data as long as necessary for the fulfillment of the purpose for which it was collected. Therefore, your personal data will be kept while your user account is still activated and therefore keep a relationship with us as user of our services.

    After your request of cancellation of your user account, we will keep your personal data duly blocked, without giving any use, (i) during a term of five (5) years after the last time we provided our services to you; and (ii) during the time necessary to exercise or defense before any claim, any kind of judicial, legal or contractual liability that may arise from the processing of such data and/or for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, which should be attended to and for which their recovery could be necessary, according with the applicable regulation in force from time to time.

    The personal data collected through cookies will be stored until cookies are deleted or until you withdraw your consent.

    Once the relevant terms have elapsed, we will erase or anonymize all your personal data.

    Furthermore, you may in any case keep activated your personal account and profile but request not to receive any promotional communications from us. In these cases, data will be kept until you request the cancellation of your personal account or delete your personal account directly and, afterwards, although duly blocked, during the following five (5) years in order to be able to respond to any eventual liabilities that could arise.

    As indicated in section 4 above, we may also collect your personal data to carry out scientific research into our machine learning processes with the exclusive purpose of the development and improvement of the quality of our technologies, products and services, so we may use this information for as long as is necessary to allow us to carry out such scientific research, without further notice to you. We will ensure the anonymization and/or pseudonymization of your personal data, the storing in a separate database (accessible only on a need-to-know basis) and we will process only the strictly necessary data to achieve our scientific research purposes.

  10. How do we share your personal data?

    We will be able to communicate your personal data to third-party collaborating entities and third-party services providers to (i) hire necessary products and/or IT services which we need to fulfill the provision of our services to you (i.e. Amazon Web Services (AWS)); (ii) to develop commercial actions of our products and services, both general and personalized.

    We have signed the relevant personal data processing agreements with all our service providers for the provision of the hired service by you, which guarantee that the data processing is carried out in accordance with our instructions and in full compliance with the applicable personal data protection regulations.

    We also will be able to communicate your personal data to public authorities, if applicable, in order to comply with applicable legal and tax obligations to which we are subject to.

  11. Third party personal data

    In case of providing us with third parties' personal data, you must have their prior consent and undertake to provide them with the information contained in this Privacy Policy, exempting us from any liability in this regard. However, we will be able to verify this fact and to adopting the corresponding due diligence measures, according to the applicable data protection regulations.

  12. Updating data

    In case of providing your personal data by email, you guarantee that such data are true, exact, complete and up to date, so that the information contained in our files and processing systems shall be always up to date and shall not contain errors. In this regard, you will be the sole responsible for any direct or indirect damage or harm that may arise as a consequence of a breach of this obligation.

  13. How do we keep your personal data secure?

    UNION AVATARS has implemented technical and organizational measures, taking into account the state of the technology, the costs of its implementation, and the nature, scope, context and purposes of the processing, to ensure a level of security appropriate to the risk identified.

    All our employees, partners and all persons involved in the processing of personal data are obliged to comply with the GDPR, as well as any applicable laws to personal data protection.

    To protect the personal data of our users we use a secure transmission method (“Secure Socket Layer” or “SSL”). SSL encryption guarantees the encrypted and complete transmission of your personal data. Notwithstanding the above, technical security in the Internet is not impregnable and there may be malicious actions made by third parties, although Linking Realities uses all the means at its disposal to prevent such actions.

    If you detect or suspect any technical vulnerability affecting UNION AVATARS Websites and/or services, please send us an e-mail.

  14. International transfer of data

    If the data processing cannot be carried out by a services provider located in a country outside the European Economic Area, we will ensure that the processing is carried out in countries with a level of protection comparable to the European Union system (European Commission adequacy decisions). In case of a country without corresponding data protection regulations, the processing will be protected by international agreements and standard contractual clauses in accordance with European legal requirements, or on the basis of other appropriate safeguards provided by law.

  15. Changes and updates to this Privacy Policy

    We reserve the right to update and/or change this Privacy Policy at any time. If we update and/or change this Privacy Policy, we will inform you via this website.

This privacy policy was published in June 2022, and last updated in May 2023.