According to the legislation in force on the protection of personal data, with special attention to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, "GDPR“ ) and Organic Law 3/2018, of December 5, on Personal Data Protection and Guarantee of Digital Rights (hereinafter, ”LOPDGDD"), we inform you of our Company Privacy Policy:
1. Personal data controller
MOEVE TRADING S.A.U., (hereinafter Moeve), with tax ID No.: A86597325, with registered office at Paseo de la Castellana, 259 A, 28046-Madrid (Spain), Data Protection Officer
dpo@moeveglobal.com.
2. Categories of personal data, purposes and legal basis for processing
The personal data provided at contracting time, as well as those provided in the future as a result of their development, will be incorporated in a MOEVE personal data protection registry for the following purposes:
1. To provide, manage, control and maintain the contractual or commercial relationship requested.
Purpose: To comprehensively manage the established contractual or commercial relationship, including the administrative, accounting, and operational procedures necessary for its execution, as well as its maintenance and monitoring.
Type of data: Identification, contact, and economic and financial data.
Legal basis: Art. 6.1.b) GDPR - Contractual performance and establishment of pre-contractual measures.
2. To provide the requested services and information, whether by the web, ordinary mail or by telephone.
Purpose: To respond to and manage requests for information, services, or products made by the interested party, whether by electronic, telephone, or postal means.
Type of data: Identification and contact details
Legal basis: Art. 6.1.b) GDPR - Contractual performance and establishment of pre-contractual measures.
3. Call recording and email confirmation.
Purpose: To record telephone conversations made to Customer Service in order to ensure better quality of service. Likewise, emails may include confirmation of receipt and reading.
Type of data: Identification, contact, and voice data.
Legal basis: Art. 6.1.f) GDPR - Moeve's legitimate interest in ensuring service quality and resolving any disputes. You can obtain additional information on how we have assessed our legitimate interest by contacting us at
dpo@moeveglobal.com.
4. Address any potential incidents that may occur, as well help Clients to perform Contracts at any time.
Purpose: To deal with any incidents that may arise in the execution of the contract with Moeve.
Type of data: Identification and contact details.
Legal basis: Art. 6.1.b) GDPR - Contractual performance and establishment of pre-contractual measures.
5. Sending commercial communications directly related to the contracted services.
Purpose: To send commercial communications, by conventional and/or electronic means (e-mails, SMS, purchase tickets), relating to Moeve's own products and services and similar to those previously contracted/purchased by the Customer, for the duration of their customer relationship.
Type of data: Identification and contact details.
Legal basis: Art. 6.1.f) GDPR - Legitimate interest of Moeve, consisting of promoting the contracting of its products and services, in accordance with the requirements and conditions set out in Law 34/2002 on information society services and electronic commerce. You can request additional information about the legitimate interest invoked by contacting
dpo@moeveglobal.com, and you can object at any time to receiving these commercial communications by writing to
derechos.arco@moeveglobal.com.
6. Analyzing risk and verifying data for fraud prevention and creditworthiness purposes.
Purpose: To analyze risk and compare or contrast your data in order to verify its accuracy and veracity in relation to entities that provide creditworthiness, credit, and fraud prevention services.
Type of data: Identification and contact details; social circumstances; transactions of goods and services; other categories of data; data derived from the use of the service.
Legal basis: Art. 6.1.f) GDPR - Moeve's legitimate interest in ensuring the lawful and proper management and development of the contractual relationship, avoiding the occurrence of unlawful and/or incorrect practices. You can obtain further information on how we have assessed our legitimate interest by contacting us at
dpo@moeveglobal.com.
7. Management of non-payments and compliance with financial obligations.
Purpose: Where applicable, to manage compliance with financial obligations in relation to any non-payments that may be made by the Customer. To this end, this financial information may be included in a file shared by the companies of the Moeve Group, which can be consulted at
www.moeveglobal.com, for the same purposes. To manage the Customer's data as a user of the Website.
Type of data: Identifying, economic, and financial data.
Legal basis: Art. 6.1.f) GDPR - Moeve's legitimate interest in knowing the solvency of its customers in order to manage possible breaches and consequent financial losses for Moeve. You can obtain additional information on how we have assessed our legitimate interest by contacting us at
dpo@moeveglobal.com.
8. Management and maintenance of Customer data as a user of the Website.
Purpose: To manage and maintain, where applicable, Customer data through the website, as well as to control, manage and maintain the services inherent.
Type of data: Identification and contact details.
Legal basis: Art. 6.1.b) GDPR - Contractual performance and establishment of pre-contractual measures.
9. Compliance with legal obligations.
Purpose: Compliance with legal obligations applicable to Moeve.
Type of data: Any categories of data processed in the context of the above purposes.
Legal basis: Art. 6.1 c) GDPR - Compliance with legal obligation.
3. Third party personal dataIn the event that the provided personal data was of a third party, the customer guarantees that he has informed the third party of this privacy policy and obtained his permission to provide Moeve his data for the stated purposes. It also ensures that the data provided is accurate and up-to-date, it being responsible for any loss or damage, direct or indirect, that might arise as a result of the non-compliance of such obligation.
4. Personal data storage period
Personal data provided shall be kept for the time necessary to fulfill the purpose stated in each case and until the contractual relationship is maintained, its deletion is not request by the interested party and should not be deleted for the fulfilment of a legal obligation or for the formulation, exercise and defense of claims.
Once the retention period has elapsed (depending on the purpose), personal data may be retained, duly blocked, for the duration of the limitation period for any legal actions and liabilities that may arise, in each case, from the specific processing activity carried out, after which it will be completely deleted.
5. Origin of the personal data
Personal data that Moeve will process is for the provision of the contracted services which have been provided mainly by the customer during the contracting process, such as name, surname, address, contact data, means of payment data. The customer is responsible for its accuracy and updating.
6. Transfers and recipients of personal dataAll data assignments which Moeve will perform are necessary for the fulfilment of the stated purposes, or are performed in order to fulfil a legal obligation regarding the following companies and Public Administrations and Courts of Justice:
- Government Agencies and Court of Justice.
- Companies providing financial solvency services, credit and fraud prevention, risk analysis and to collate or analyze data in order to verify the accuracy and veracity of the same and companies providing payment services.
- Insurance, reinsurance, guarantee funds companies or any other third party acting as a guarantor of the risk or transactions when the customer uses Moeve means of payment, in case the issuer of the payment means has agreements with the companies indicated and for the sole purpose of identifying his registration as a Moeve cardholder.
- Moeve suppliers: for its IT infrastructure and customer management using the “cloud computing" model.
- Moeve has hired Google, Weborama Ibérica, S.L. and Salesforce.com Inc. as Suppliers for the purpose of measuring web traffic and customer behavior. Information on Cookies Policy from Moeve and its suppliers available to the customer in their websites:
In the event of any international transfer, it will be carried out in compliance with the criteria and requirements of the regulations in force, through the adoption of appropriate legal guarantees, which may consist of the formalization with the recipient of the data of (i) Standard Contractual Clauses approved by the European Commission to legitimize the international transfer of data to third countries or (ii) in another valid legal instrument that allows guaranteeing an adequate level of protection equivalent to that of the European Economic Area.
Further information on international transfers can be obtained by contacting our DPO at
dpo@moeveglobal.com7. Customers’ RightsThe User may exercise before MOEVE TRADING, S.A.U., if applicable, his access rights, rectification or suppression, data processing limiting, opposition, portability and opposition to automated individual decisions. He may also revoke his consent if he has granted it for any specific purpose, and may modify his preferences at all times.
The Customer may exercise his rights in the e-mail address:
derechos.arco@moeveglobal.com, or at the registered office of MOEVE TRADING, S.A.U. (Ref.: Data Protection-Legal Department), at Paseo de la Castellana, 259 A, 28046-Madrid (Spain). The Customer is informed that he can direct any claim regarding personal data protection to the Spanish Data Protection Agency
www.aepd.es, Spain Control Authority.